Prospective import-policy amendments cannot impose new Actual User registration conditions on earlier warehoused newsprint imports.

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....Import-policy amendments requiring an importer warehousing newsprint to be an RNI-registered Actual User operate prospectively from 3 June 2016 and do not invalidate earlier imports. Where the applicable customs exemption contains no RNI-registration or Actual User requirement, non-registration alone does not defeat the exemption. Customs should not independently characterise imports as contrary to the Foreign Trade Policy without a DGFT reference on the disputed policy interpretation. Confiscation and penalties for alleged clearance to dummy units require the Department first to establish foundational evidence of illicit import, improper clearance, or culpable conduct; rebutted procedural allegations and missing relied-upon material cannot support those consequences.....