Provisional assessment cannot be coupled with full duty demand and extra security when no separate safeguard is justified.

Where duty had already been directed at the full rate and the classification list was kept provisional, insisting on both provisional assessment safeguards and additional security was unjustified. The article explains that provisional assessment under Rule 9B may protect revenue pending enquiry, but once the maximum duty leviable is fixed for payment, there is no separate basis to compel execution of a B-13 bond and furnish a bank guarantee. The concurrent demand for full duty payment and provisional security was treated as an abuse of the Rule 9B process, and the assessment was to be finalised without those additional requirements.

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Issues: Whether, when duty was directed to be paid at the full rate and the classification list was kept provisional, the appellants could still be compelled to execute a B-13 bond and furnish a bank guarantee.

Analysis: The assessment was treated as provisional under Rule 9B even though the appellants were already directed to pay the maximum duty leviable. The direction for provisional assessment was intended to safeguard revenue pending enquiry, but once the full rate of duty had been fixed for payment, there was no separate justification for insisting on both provisional assessment machinery and additional security. The concurrent insistence on full duty payment and provisional safeguards was found unjustified and an abuse of the process under Rule 9B.

Conclusion: The appellants were not required to execute the B-13 bond or furnish the bank guarantee, and the assessment was to be finalised.

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