https://www.taxtmi.com/caselaws?id=41361 The Sea Customs Act operated as a complete code for levy, assessment, refund, appeal and revision of customs duty, so a civil suit to recover duty said to have been wrongly collected was barred by necessary implication. Because the statute created the liability and provided a full remedial scheme, a claimant could not bypass the statutory appeal and revision process by suing directly for refund merely because no appeal was filed. Civil court jurisdiction remained available only where the customs authority acted without jurisdiction, in breach of fundamental judicial procedure, mala fide, or under an unconstitutional statute. en-us Mon, 01 Sep 1969 00:00:00 +0530 Thu, 23 Feb 2017 16:50:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=41361 The Sea Customs Act operated as a complete code for levy, assessment, refund, appeal and revision of customs duty, so a civil suit to recover duty said to have been wrongly collected was barred by necessary implication. Because the statute created the liability and provided a full remedial scheme, a claimant could not bypass the statutory appeal and revision process by suing directly for refund merely because no appeal was filed. Civil court jurisdiction remained available only where the customs authority acted without jurisdiction, in breach of fundamental judicial procedure, mala fide, or under an unconstitutional statute. Case-Laws Customs Mon, 01 Sep 1969 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=41361