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2025 (6) TMI 934

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....quirements of their customers. The basic raw material is RPO. For the above purpose, the appellants had imported RPO through various ports such as JNPT, Nhava Sheva; Pipavav and Mundra sea ports. During the disputed period i.e. from 19.01.2017 to 09.08.2019, the appellants had imported 'Rubber Processing Oil' under 79 Bills of Entry (B/Es) at the above ports by classifying it under Customs Tariff Item (CTI) 2707 9900 and claimed concessional rate of Basic Customs Duty (BCD) at 2.5% under Serial No. 121E of Notification No. 12/2012-Customd dated 17.03.2012 and Serial No. 143 of Notification No. 50/2017-Customs dated 30.06.2017. Directorate of Revenue Intelligence, Mumbai Zonal Unit (DRI) had developed an intelligence that the appellants had mis-declared the classification of the imported RPO and had alleged that such imported goods are correctly classifiable under CTH 2713 9000 with applicable BCD at the rate of 5% vide Sr. No. 130 of Notification No.12/2012-Customs dated 17.03.2012 and Sr. No. 147 of Notification No.50/2017-Customs dated 30.06.2017. After conducting detailed investigation including examination of various documents, test reports relating to such imports, DRI had iss....

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....cation No. 24/2021-Customs (N.T./CAA/DRI) dated 17.03.2021 for adjudication of the present case by the Principal Commissioner of Customs, NS-I, Nhava Sheva. Accordingly, the adjudicating authority had passed the impugned order 07.12.2024 by classifying the impugned goods under CTI 2713 9000 and rejecting the classification adopted by the appellants under CTI 2707 9900 and denying the concessional duty/exemption claimed by them. Further, in the said impugned order, the learned adjudicating authority had re-assessed the finally assessed B/Es and provisionally assessed B/Es separately; he had also confirmed the differential duty demanded in the SCN dated 23.02.2021, under Section 28(4) of the Customs Act, 1962 by invoking the extended period for the finally assessed B/Es for an amount of Rs. 2,25,49,590/-and under Section 18 ibid for provisionally assessed B/Es for an amount of Rs.64,34,234/-. He further confiscated the impugned goods under Section 111(m) ibid and imposed Redemption fine of Rs.10,00,00,000/- in lieu of confiscation goods under Section 125(1) ibid and also imposed penalties on the appellants under Section 112(a) ibid. Furthermore, he had also appropriated Rs.54,83,549/....

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....during investigation, on the basis that the same quality of goods which have been tested earlier, have been imported in the present consignments. Further, the adjudicating authority had discarded the test reports submitted by the appellants which were favourable to them, and had incorrectly came to the conclusion that the imported RPO is having aromatic constituents less than 50% by weight. Learned Advocate submitted that out of total 79 B/Es under dispute, the appellants had carried out in-house testing of 64 B/Es, in which the aromatic constituents by weight are indicated as more than 50% and such test reports have been submitted during the investigation, and adjudication. An illustrative case of such B/E and test report has also been provided as part of the appeal papers in the form of Annexure-1. Therefore, he stated that these facts have not been properly considered by the adjudicating authority.  4.3 Learned Advocate further submitted that in terms of Chapter Note 2 to Chapter 27, similar oils and products with the predominance of aromatic constituents obtained by the distillation of low temperature coal tar or other mineral tar, by the 'stripping' of coal gas, by the....

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....tion of penalty on the appellants in the impugned order is not sustainable. In view of the above, he pleaded that on the above basis, their appeal may be allowed. 5. On the other hand, learned Authorised Representative (AR) appearing for Revenue, reiterated the findings made by the learned Principal Commissioner of Customs in the impugned order and stated that on the basis of the detailed investigation and findings made, the impugned order is sustainable. Therefore, he stated that the appeals filed by the appellants may be dismissed. 6. We have heard both sides, examined the case records and the additional submissions made during the course of hearing, paper books submitted by both sides.  7. The issue involved herein is to decide the following: (i) determine the classification of goods imported by the appellants as to whether, the same merits classification under Customs Tariff Heading (CTI) 2707 9900 described as 'Rubber Processing Oil (RPO)' as claimed by the appellants; or, is it classifiable under CTI 2713 9000 described as 'Other residues of Petroleum oils or oils obtained from bituminous minerals' as determined in the impugned order, for deciding on ap....

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....dard IS 15078:2001, which inter alia prescribe the maximum Aniline point as 55˚C.  (iv) The impugned goods under dispute is covered under 79 B/Es i.e., 60 B/Es relating to imports under JNCH, Nhava Sheva seaport;  17 B/Es relating to imports under Pipava seaport and 2 B/Es relating to imports under Mundra seaport.  (v) In respect of 18 B/Es, the appellants on the basis of their in-house chemical test reports inter alia indicating the aromatic constituents being less than 50%, had paid the differential duty of Rs.46,85,539/- along with applicable interest of Rs.7,98,010/- during the time of investigation and informed the same to the department vide their letters dated 04.12.2019 and 09.12.2019. (vi) The appellants had claimed that in respect of imports under 64 B/Es, the in-house test reports indicate that the aromatic constituents are more than 50%; however, only a specimen copy of such in-house test report was submitted as Annexure-1. (vii) In respect of 5 previous test reports of JNCH, Nhava Sheva; 4 previous test reports of Pipava port and 1 previous test report of Mundra port, it is indicated in all such test reports that the imported goods are e....

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....FF (Refer Section 2) THE GENERAL RULES FOR THE INTERPRETATION OF IMPORT TARIFF Classification of goods in this Schedule shall be governed by the following principles:  1. The titles of Sections, Chapters and sub-chapters are provided for ease of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes and, provided such headings or Notes do not otherwise require, according to the following provisions:  2. (a) Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as presented, the incomplete or unfinished articles has the essential character of the complete or finished article. It shall also be taken to include a reference to that article complete or finished (or falling to be classified as complete or finished by virtue of this rule), presented unassembled or disassembled.  (b) Any reference in a heading to a material or substance shall be taken to include a reference to mixtures or combinations of that material or substance with other mate....

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....bove, packing materials and packing containers presented with the goods therein shall be classified with the goods if they are of a kind normally used for packing such goods. However, this provision does not apply when such packing materials or packing containers are clearly suitable for repetitive use.  6. For legal purposes, the classification of goods in the sub-headings of a heading shall be determined according to the terms of those sub headings and any related sub headings Notes and, mutatis mutandis, to the above rules, on the understanding that only sub headings at the same level are comparable. For the purposes of this rule the relative Section and Chapter Notes also apply, unless the context otherwise requires. THE GENERAL EXPLANATORY NOTES TO IMPORT TARIFF 1. Where in column (2) of this Schedule, the description of an article or group of articles under a heading is preceded by "-", the said article or group of articles shall be taken to be a sub-classification of the article or group of articles covered by the said heading. Where, however, the description of an article or group of articles is preceded by "- -", the said article or group of....

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....specifies the various categories of imported goods in a systematic and well-considered manner, in accordance with an international scheme of classification of internationally traded goods, i.e., 'Harmonized Commodity Description and Coding System' (HS). Accordingly, goods are to be classified taking into consideration the scope of headings / sub-headings, related Section Notes, Chapter Notes and the General Rules for the Interpretation (GIR) of the First Schedule to the Customs Tariff Act, 1975. Rule 1 of the GIR provides that the classification of goods shall be determined according to the terms of the headings of the tariff and any relative Section notes or Chapter notes and thus, gives precedence to this while classifying a product. Rules 2 to 6 provide the general guidelines for classification of goods under the appropriate subheading. In the event of the goods cannot be classified solely on the basis of GIR 1, and if the headings and legal notes do not otherwise require, the remaining Rules 2 to 6 may then be applied in sequential order. Further, while classifying goods, the foremost consideration is the 'statutory definition', if any, provided in the Customs Tariff Ac....

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....he contending classification for determining correct classification of the imported goods. The scope of goods covered under CTI 2707 9900 relates to "-- Other" under the heading "Oils and other products of the distillation of high temperature coal tar; similar products in which the weight of the aromatic constituents exceeds that of the non-aromatic constituents", other than Benzol, Toluol, Naphthelene and other aromatic hydrocarbon mixtures described in CTI 2707 5000"; and on the other side, the department has re-classified the impugned goods covered under CTI 2713 9000 as "- Other residues of petroleum oils or of oils obtained from bituminous minerals".  Hence, we need to closely look at the classification under the First Schedule to the Customs Tariff Act for arriving at proper conclusion on the classification of the impugned goods. The relevant headings and their tariff entries in the First Schedule to the Customs Tariff Act, 1975 of contending Chapter headings 2707 and 2713 are extracted as below: "CHAPTER 27 Mineral fuels, mineral oils and products of their distillation; bituminous substances; mineral waxes xxx     xxx    &nbsp....

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....tar, by the  'stripping' of coal gas by the processing of petroleum or by any other process covered under  CTH 2707 99;  Further, the first broad category of products are further grouped under various CTIs as follows: (a) Benzol (benzene), toluol (toluene), xylol (xylenes) and solvent naphtha covered under CTI 2707 1000; 2707 2000; 2707 3000; (b) Naphthalene oils and crude naphthalene covered under CTI 2707 4000; (c) Anthracene oils and crude anthracene, Phenolic oils, Pyridine, quinoline and acridine bases covered under CTI 2707 5000; (d) Creosote oils covered under CTI 2707 9100; and the second broad category of goods cover the following: (e) Similar oils and products with a predominance of aromatic constituents obtained by the distillation of low temperature coal tar or other mineral tar, by the  'stripping' of coal gas by the processing of petroleum or by any other process, covered under CTH 2707 9900; 9.2 Similarly, by applying same GIR 1, it could also be seen that Chapter Heading 2713 covers within its scope and ambit, mainly of three broad categories of goods:  (i) first one i.e., "Petroleum c....

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....hen the appropriate classification of the impugned goods would be under CTI 2713 9000.  9.4 We also find that the Central Board of Excise & Customs (CBEC) vide Circular No.11/89 dated 13.02.1989 had examined the issue of classification of Speciality Oil (Processed Oil) in the context of doubts expressed for classification whether under sub-heading No. 2719.50 or 2713.39/2713.30 or under sub-heading No. 2707.90 of the Schedule to the Central Excise Tariff Act, 1985 being a discussion point in South Zone Tariffcum-General Conference of Collectors of Central Excise. Based on the discussion held in the said tariff conference and in consultation with the Deputy Chief Chemist, CRCL, the issue was decided by the Board and communicated to the filed formations for uniformity in assessment. In such instructions issued by CBIC also it is found that basis for classification of Rubber Process Oil is based on the fact whether the aromatic constituents exceeds that of the non-aromatic constituents, which is in supportive of our views on classification of impugned goods. The extract of the said circular is given below: "Circular No. 11/89, dated 13-2-1989 F. No. 87/2/88-C....

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.... classification of such goods under Heading No. 27.10 of CET is also ruled out since aromatic constituents in this case predominate over non-aromatic constituents. The Deputy Chief Chemist, CRCL, has opined that the more appropriate sub-heading for the goods in question would be 2707.90 as 'similar products in which the weight of aromatic constituents exceeds that of the non-aromatic constituents. The Board agrees with the views of the Deputy Chief Chemist in the matter. 4. Accordingly, it is hereby clarified that the 'Speciality Oils' (Processed Oils) in question would be appropriately classifiable under sub-heading No. 2707.90. 5. The above guidelines may be brought to the notice of the lower field formations and the trade interests also may be suitably advised." 9.5 From the impugned order, we also note that there is a specific BIS standards prescribed in respect of petroleum based oils for Rubber industry provided as IS 15078: 2001. Some of the characteristics and the standard requirements for Type-I Aromatic RPO are given at paragraph 1.4(xii) of the impugned order at internal page 7 of 67. This include Aniline point specified at the maximum of 55˚C, ....

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....9 Since the fact that non-aromatic constituents by weight exceeds that of the aromatic constituents, i.e., in other words, the aromatic constituents is less than 50%, in all the above imported consignments of 18 B/Es through JNCH port, Nhava Sheva the appropriate classification of such goods covered under these 18 B/Es would be under CTI 2713 9000 and not under CTI 2707 9900, as claimed by the appellants. Further, the appellants vide letter dated 09.12.2019 had also informed the department that they had made payment of differential duty of Rs.25,26,471/- along with interest of Rs.5,49,360/- towards the remaining consignments, where they had accepted that the aromatic constituents is less than 50%. Thus, the importer had made a total payment of Rs.46,85,539/- along with interest of Rs.7,98,010/- i.e., total amount of Rs.54,83,549/- during investigation.  9.8 We further find that CBEC had issued instructions vide Circular No. Customs dated 18.07.2017, wherein detailed guidelines have been provided for re-testing of samples, in case the first test result of a sample taken upon arrival of goods declared for importation shows an adverse finding, on the basis of the request su....

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....de only after being reasonably sure that the desired re-testing facilities exist at the laboratory/institution. d. Re-test should be made only on the remnants of the samples originally tested or on duplicate representative sealed samples in the custody of the Customs. Further, to avoid delays, samples for second tests shall be marked as "immediate" before sending to the laboratory. In a case it may so happen that fresh samples have to be drawn, then such sampling should be done in the presence of the importer or his representative/customs broker. e. The requests for re-test of samples on the ground that the original sample was not representative should be entertained only if the consignment is still in Customs control. At the time of drawing the samples, the importer or his representative shall be present and certify that the samples drawn are representative. f. The competent authority shall consider the results of the re-test without prejudice to the results of the first test. In case there is a variation in the results of the first test and the re-test, the competent authority shall take the decision relying upon either of the tests specifying the groun....

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....concession claimed by the appellants. However, during investigation, the custom house laboratory at  JNCH, Nhava Sheva; Pipava and Mundra have given the test reports in respect of imported consignments by the appellants during the disputed period which indicated that the importer goods does not meet the requirement of petroleum based process oil for rubber industry as per IS 15078:2001 in respect of the specified parameters like Kinematic viscosity at 100˚C, density, Aniline Point; and that the aromatic constituents are of less than 50% by weight. Accordingly in respect of 25 B/Es of imports under JNCH, Nhava Sheva where the imported goods have been cleared on the basis of previous test reports, as mentioned in the respective B/E, since the requirement of adherence to BIS standards for RPO and aromatic constituents not being above 50% by weight, these goods are also alleged by the DRI investigation and the adjudicating authority had classified it to be under CTI 2713 9000 and not under CTI 2707 9900, as claimed by the appellants. The list of such B/Es are given below: Sr. No. Bill of Entry No. Bill of Entry Date Previous Test Report (PTR) 1. 825298....

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....ical supply chain involved, it is evident that the aromatic constituents of the imported Rubber Process Oil was less than 50%. Given the past behavior of the Noticee, their in-house test reports showing aromatic constituents as more than 50% has no credibility. Moreover, only test reports of the Customs laboratory, other suitable Govt. laboratories or private accredited laboratory, can be considered for the said purpose. Further, the test reports were not submitted at the time of filing of the Bills of Entry and were submitted at a later stage after several years of import. The submission of their in-house test reports by the Noticee appears to be an afterthought and therefore, cannot be relied upon. In view of the above, I discard the test reports submitted by the Noticee and conclude that the Rubber Process Oil consignments imported by the Noticee were having aromatic constituents less than 50%; thus, they were wrongly classified under CTI 27079900, instead of the correct CTI 27139000.  xxx      xxx      xxx      xxx 4.10.2.....From the above, I find that all the consignments of &#39....

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....nts where the aromatic constituents were more than 50%, by simply stating that it is an afterthought. In an illustrative case of B/E No. 3456252 dated 30.05.2019 covering import of RPO at JNCH, Nhava Sheva port, the appellants had submitted the chemical analysis report showing aromatic constituents as % of mass of 72.58%, the extract of which is placed below. However, such factual detail which is crucial in determination of the classification of impugned goods has not been examined in the impugned order.  Therefore, we do not find any merits in such findings recorded by the adjudicating authority for classification of the imported goods under CTI 27139000 in the rest of the B/Es, other than those discussed as above in preceding paragraph at 9.7 above. 10.2 We further find that at the time of investigation, the test reports conducted by the departmental CRCL laboratory on various import consignments made by the appellants were sought from the jurisdictional Customs/CRLC authorities covering the entire disputed period. In respect of the majority of imports covered under 60 B/Es imported through JNCH, Nhava Sheva port, the Joint Director, JNCH CRCL Laboratory had replied vi....

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....mported goods in the earlier cases of imports under the business entity M/s Sah Petroleums Limited and the Tribunal's order dated 26.04.2017 in that case has also been shown as the ground for deliberate act of misdeclaration.  10.4 In a number of cases, the Tribunal have held that in cases of classification disputes, extended period cannot be invoked and penalty cannot be imposed claiming it as mis-statement, as the customs statute provide for modifying self-assessment made by an importer through reassessment by proper officer. In the case of Midas Fertchem Impex Pvt. Ltd. Vs. Principal Commissioner of Customs, ACC (Import), New Delhi in Final Order No. A/50027-50031/2023 dated 13.01.2023 - 2023 (384) E.L.T. 397 (Tri.-Del.), a similar view was taken by the Tribunal by holding that wrong classification or claim of an ineligible notification or wrong selfassessment of duty by an importer will not amount to mis-statement or suppression. Further, the Hon'ble Supreme Court in the case of Pushpam Pharmaceuticals Company Vs. Collector of C.Ex., Bombay - 1995 (78) E.L.T. 401 (S.C.) in Civil Appeal No. 1957-58 of 1988 vide judgement dated 28.03.1995 have held the act of proviso clau....

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....nded period of limitation under Section 18(4) ibid. Further, the requirement of declaring the requisite particulars by the importer in the form of filing B/E as prescribed under the Regulations, indicating the various particulars of the imported goods including description, classification, value of goods, duty concession/ exemption claimed by them etc., are to enable self-assessment under Section 17 ibid and the same cannot be claimed as the grounds for invoking the extended period under the category of mis-declaration. It is also a fact on record, that the adjudicating authority on re-assessment of finally assessed B/Es had confirmed the differential duty by invoking the extended period of limitation under Section 18(4) ibid. In view of the above factual position and as there is no specific grounds or evidences placed on record by the investigation in the SCN dated 23.02.2021 and that there is no specific findings recorded in the impugned order proving the ingredients of mis-declaration or suppression of facts with an intention to evade duty, we are of the considered view that the invocation of extended period in the present case does not stand the scrutiny of law. 10.6 From th....

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....f notice, [Words "where it is possible to do so," omitted by the Finance Act, 2018, w.e.f. 29-3-2018.][***] in respect of cases falling under sub-section (4): [Inserted by the Finance Act, 2018, w.e.f. 29-3-2018] [Provided that where the proper officer fails to so determine within the specified period, any officer senior in rank to the proper officer may, having regard to the circumstances under which the proper officer was prevented from determining the amount of duty or interest under sub-section (8), extend the period specified in clause (a) to a further period of six months and the period specified in clause (b) to a further period of one year: Provided further that where the proper officer fails to determine within such extended period, such proceeding shall be deemed to have concluded as if no notice had been issued.]" Since, in the present case the SCN has been issued invoking the extended period, it is claimed by the appellants that the time limit of one year would apply from the date of issue of the SCN on 23.02.2021. However, as explained in the impugned order at paragraph 4.2, in view of the CBIC's instructions Customs dated 17.03.2021 issued in purs....

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....ect of Central Excise matters, have held that the facts of each case has to be examined to find out whether there were circumstances or insurmountable exigencies which made it impracticable for the adjudication to take place, as has been held by the Hon'ble Delhi High Court in Swatch Group of India Pvt. Ltd. Vs, Union of India 2023 (386) E.L.T. 356 (Del.). In the Kopertek case (supra) the Tribunal had set aside the demands in all 209 SCNs on the ground that there was no plausible explanation as to why it was not possible for the Adjudicating Authority to complete the adjudication process within the stipulated time.  11.3 We find that in the present case, the adjudicating authority had given detailed explanation of the grounds why he could not adjudicate the case, and the case was kept under call book category, without adjudication, due to the specific instructions of the CBIC relating to the matter of Canon India case pending before the Hon'ble Supreme Court and the permission had been given for extension of the time period for adjudication of the case by the proper authority in terms of Section 28(9) of the Customs Act, 1962.  11.4 Further, in the case of Canon Ind....

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....relevant paragraphs of the said order is extracted and given below: "21. The next issue to be decided in the present appeals is whether the goods are classifiable under Chapter sub-heading 2707 9900 as canvassed by the revenue or 2710 1960 as canvassed by the Appellants or under 2713 9000 as alternatively pleaded by the Appellants. We find that goods were purported to be classified under Chapter sub-heading 2707 9900 by the revenue on the ground that Rubber Process Oil (RPO) which meets the requirements stipulated in the Chapter Note 2 of Chapter 27 would remain appropriately classifiable under sub-heading 2710 and that in case where the weight or aromatic constituent exceeds that of non-aromatic constituents then such product would appear more appropriately classifiable under 2707 subject to meeting the requirements. The Chapter Note 2 of Chapter 27 read as under : Reference in heading 2710 to "petroleum oils and oils obtained from bituminous minerals" include not only petroleum oils and oils obtained from bituminous minerals but also similar oils, as well as those consisting mainly of mixed un-saturated hydrocarbons, obtained by any process, provided that the we....

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....ed goods RPO cannot be classified under Chapter sub-heading 27.07 as it is not applicable to residues of petroleum oils or of oils obtained from bituminous minerals. Further even as per the HSN Explanatory Notes to said chapter the correct classification would be under Chapter sub-heading 271390 00. The more specific tariff heading is ought to be assigned to the goods in case if two headings are equally applicable. We therefore hold that the raw RPO imported by the Appellants would merit classification under chapter heading 2713.90 and would be liable to duty accordingly. 23. The demands against the Appellants have also been raised by invoking extended period of limitation in respect of previous imports. We find that during the course of earlier imports also the samples were drawn by the Customs Authorities and were sent for testing. The aromatic contents were found to be less than 50% by weight and the goods were allowed to be cleared. In such view of facts it cannot be said that the Appellants have suppressed any facts from department. Further we find from the bill of entry for home clearances that there is no mention of any provisional assessment of the same which shows....

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....p; The judgment impugned does not warrant any interference. The appeals are dismissed. However, question of law pertaining to the classification of goods under the Customs Tariff Act is left open. ........................J. (J. CHELAMESWAR) ........................J. (S. ABDUL NAZEER) NEW DELHI September 8, 2017 13.1 In view of the foregoing discussions and analysis, and on the basis of the orders passed by the Tribunal, particularly in the identical set of facts in the case of Sah Petroleums Ltd., (supra) which was also upheld by judgement of the Hon'ble Supreme Court dated 08.09.2017, we are of the considered view that the impugned order dated 07.12.2024 confirming the adjudged demands by invoking the extended period of limitation under Section 28(4) of the Customs Act, 1962 and consequent confiscation of imported goods, imposition of redemption fine, penalties on the appellants is not legally sustainable. Since, the demand of duty under Section 18 ibid on re-assessment of provisionally assessed B/Es did not place on record any specific chemical test report(s) as evidence in support of the nonaromatic cons....

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.... 9900 as claimed by them, and are right classifiable under the alternate classification of CTI 2713 9000 as determined by the department. Therefore, the total differential duty of customs along with interest paid by the appellants for an amount of Rs. 54,83,549/- and appropriated in the impugned order dated 07.12.2024 at paragraph 5(i) is sustained.  14. In the result, the impugned order dated 07.12.2024 passed by the learned adjudicating authority is set aside to the above extent and the appeal filed by the appellants are partly allowed in their favour.  (Order pronounced in open court on 06.06.2025)  ============= Document 1 Indian Customs EDI System - Imports V1. 58001 INCH, NEAVA SHEVA, TAL: DRAN, DIST-RAIGAD-400707 BILL OF ENTRY FOR ECVE CONSUMPTION [Custom Stn: INNSA1] J CHA : AABCI0301CCE001 [M/S.TOCC SHIPPING PVT. LTD. BE No/Dt./cc/Typ:3456252/30/05/2019/N/= Importer Details : 0392057387 PAN : AABCS52958FT001 AD Code : 6360156 GP PETROLEUMS LTD. 1 : PLOT NO. 5 TO 14, 38. DEEHAN & SHAW, I NOL. EST., VALIV VILL. VASAI 2, THANE, MAHARASHTRA Transaction Payment Method : 401201 IGM No : 2225914/30/05/2019 Port Of L....

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.... F BSIU2929147 11 2225914 F BSIU2929337 12 2225914 F BSIU2933609 13 2225914 F BSIU2979770 14 2225914 F CAIU2577349 15 2225914 F CAIU3413062 16 2225914 F CAIU3651440 17 2225914 F GESU2872120 18 2225914 F GESU3086825 19 2225914 F HDX02055008 20 2225914 F IRSU2053655 21. 2225914 F IRSU2070040 22 2225914 F IRSU2246973 23 2225914 F IRSU2410388 24 2225914 F IRSU2415494 25 2225914 F IRSU2553270 26 2225914 F IRSU2569894 27 2225914 F IRSU2596360 28 2225914 F IRSU2612033 29 2225914 F IRSU2613071 30 2225914 F IRSU2711530 31 2225914 F IRSU2739265 32 2225914 â‚£ IRSU2776253 33 2225914 F IRSU2801377 34 2225914 F IRSU2810487 35 2225914 F IRSU2830400 36 2225914 F PARU2058086 37 2225914 F PARU2413745 38 2225914 F PAR02468141 39 2225914 F PARU2612217 40 2225914 F PARD2687896 41 2225914 F PCIU1709290 42 2225914 F SSAU2864412 43 2225914 F SBAD2868762 44 2225914 F SBAU2889549 45 2225914 F SBAU2968859 45 2225914 F SKIU2045660 GSTIN Details 47 2225914 .F SKI02054810 48 2225914 F WOSU3209090 Duty Rc. Payable: Sixty Nine and Forty Four only 6947344 SKIU2045660 GSTIN Details GSTIN Details Document No Typ Stato....

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....00707 TEL: 022-27240261; Enmil ID. [email protected] File No: S/16-16/2020-21/LAB/JNCH Date: 29,07.2020 To The Senior Intelligence Officer, CI Cell, DRI, MZU. Sir, Sub: Enquiry in respect of 'Rubber Process Oll' imported by M/s. GP Petroleums Ltd ._ reg. Please refer to your letter F. No. DRI/MZU/CI/INT-164/2019/1756 dated 28.05.2020. In this connection it is mentioned that as per the data available in JNCH Laboratory, only two samples described as 'Rubber Process Oil' imported by M/s. GP Petroleums Ltd. having BE No. 4750474 dt. 10.01.2018 and 7695935 dt. 18.08.2018, during the period from 2014 onwards till date had been tested in JNCH Laboratory. Out of the two, only one test report is traceable (BE No. 7695935 dt. 18.08.2018) and a copy of the same is enclosed. For the second sample (BE No. 4750474 dt. 10.01.2018), copy of analysis report recorded in chemist's register is enclosed for necessary action. Yours faithfully 29/7/2020 V. Suresh Joint Director, NFSG JNCH Laboratory Nhava Sheva Document 4 brigida! 3 copy Indian Customs EDI System . Importe VaSR001 .JNCH, NHAVA SHEVA, TAL: URAN, DIST-RAIGAD-400707 BILL OF ENTRY FOR HOME. CONSUMPTION :....

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....C Inv No & Dt. ": EXPRPO21/03/1691 21/03/2016 Item Details sìno RITC Description .RSP. amc.(Rs. ) Load PRC Qty Unit Price CTH C. Noon C NSNu Cus. Duy Rt BCD ) Unit Ass Val CÊTH E. Notn E:NSNC Exc DEy RC CVD. amt (.Rs .. Sec & Higher 201079900 Educacional Cess on Edu. Cess on CVD - RUBBER ByD PROCESSING 52720 OIL (FLEXI SAGI 0. 0.400 % 00 2.50 $6:420 of bo. 7.50 Customs Educational Cess: 2:00 8 "Customs Sec & Higher Edu. Cess. 1.00 % 3.80 Addl Duty (Imports) 019/2006 4.00 % 105.60. Rs. .2989379.89 Page Total 659149.90 2989379.89 RST .BE. Gross Toral .: RS 659149.90 BCD Rs . 74734 50 NCD Duty Rs: 0.00 0.00 ANTID PRS. 0.00 SAFEGUARD DuLy 25. 0.00 CVD Rs. 428976 . 0,0 Sch 2 Spl Excise Duty Rs. 0.00 CESS Rs. 0.00 GSIA: R's TTA Rs. 0.00 :10074.20 Edu. Cess CVD. Rs 0.00 Customs Edu, 2.8: Health CVD. Rs : 0.00 Add! Duty. 140328:10 10 SHE. Cess CVD Rs : 0.00 SH . Cust. Edu CAAS .R'S: 5037. Duty Payablet RS: 6591.50 Rs Six Lakh Fifty Nine Thousand One Hundred and Party only Sec & Higher 201079900 $6:420 of bo. 7.50 Educacional Cess on Edu. Ce....