https://www.taxtmi.com/caselaws?id=783664 The dominant issues were (i) validity of extension of time under s.110(2) of the Customs Act and (ii) liability of a customs broker/persons as "importer/beneficial owner" and for penalties. The Tribunal held that, by virtue of Central Govt notifications appointing DRI officers as Customs officers, the ADG, DRI was competent to extend time under s.110(2); however, the extension order is quasi-judicial and must be a speaking order passed after hearing, and the bare reliance on "pandemic" without substantiation rendered the extension unsustainable. Non-mention of DIN, though contrary to CBIC circulars, did not nullify the s.110 proceeding absent an express statutory consequence. On merits, "beneficial ownership" and forgery were not proved against the broker/persons, so penalties under ss.112, 114A and 114AA were set aside and s.117 penalty reduced; confiscation was upheld due to misdeclaration and Plant Quarantine violations, and the appeal was partly allowed. en-us Wed, 17 Dec 2025 00:00:00 +0530 Fri, 19 Dec 2025 15:05:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783664 The dominant issues were (i) validity of extension of time under s.110(2) of the Customs Act and (ii) liability of a customs broker/persons as "importer/beneficial owner" and for penalties. The Tribunal held that, by virtue of Central Govt notifications appointing DRI officers as Customs officers, the ADG, DRI was competent to extend time under s.110(2); however, the extension order is quasi-judicial and must be a speaking order passed after hearing, and the bare reliance on "pandemic" without substantiation rendered the extension unsustainable. Non-mention of DIN, though contrary to CBIC circulars, did not nullify the s.110 proceeding absent an express statutory consequence. On merits, "beneficial ownership" and forgery were not proved against the broker/persons, so penalties under ss.112, 114A and 114AA were set aside and s.117 penalty reduced; confiscation was upheld due to misdeclaration and Plant Quarantine violations, and the appeal was partly allowed. Case-Laws Customs Wed, 17 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783664