HC denies customs duty recovery under Sections 28 and 147, upholding no liability on importers for agent's actions

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....The HC upheld the decision of the CESTAT, dismissing the appeal against the respondents regarding recovery of customs duty under Sections 28 and 147 of the Customs Act, 1962. The court found no basis to impose liability on the respondents for the wrongful acts of their agent, noting the respondents' demonstration of bona fide conduct through payment evidence. The statements implicating the agent in malafide activities were insufficient to extend liability to the principal importers under Section 147(2). As the appellant's contentions were confined to factual disputes resolved in favor of the respondents, no substantial question of law arose warranting interference. Consequently, the appellant's appeal was dismissed, affirming the Tribunal's order in favor of the respondents.....