Penalty Imposed u/s 112(a) of Customs Act for Collusion and Forgery to Evade Duty; Fraud Nullifies Actions.

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....Levy of penalty u/s 112(a) - There is admitted case of collusion and forgery plus concoction of documents, including presenting and filing of false and incorrect documents (invoice), to evade Customs duty by the importer and the appellant company. Further, the present proceedings are for imposition of penalty and not for demand of duty under Section 28(4). The show cause notice on this appellant is not under Section 28(4) of the Customs Act. Fraud vitiates everything. - AT....