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Seizure of consignments by the surveillance team violated the Standard Operating Procedure applicable during the Model Code of Conduct; consequently the handover to Revenue was vitiated and the High Court's finding to that effect is sustained, with release directed to Sequel Logistics as the person from whom the goods were seized. A notice issued in reassessment proceedings against the courier employee was arbitrary because he was a custodian not shown to be owner, and was quashed. Third party ownership claims must be pursued under the statutory requisition/claim procedure rather than by writ.
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