Penalties under Regulation 22 of Customs Brokers Licensing Regulations, 2013 cannot apply retroactively to actions before June 21, 2013.

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....Penalty under Regulations 22 of Customs Brokers Licensing Regulations, 2013 - provisions for imposing penalty were not in existence under the provisions of CHA LR 2004. Therefore, the same cannot be brought into effect before 21.06.2013 on which date CBLR 2013 having the provisions for imposing penalty came in to effect. - AT....