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TMI Blog2001 (8) TMI 424X X X X Extracts X X X X X X X X Extracts X X X X ..... ch centered around the questions as to whether in the facts of the case there is full and true disclosure of applicant s duty liability, and whether the provisions of Section 127B(1) of the Act are satisfied. Accordingly, in terms of Section 32D read with Section 32A(7) of the Central Excise Act, 1944, Order No. 1/2000, dated 14-12-2000 constituting a Special Bench of five Members was issued. The Chairman directed that the case shall be heard by the Special Bench for a decision, inter alia, on the following issues : 1. Does the term containing a full and true disclosure of his duty liability which has not been disclosed before the proper officer appearing under sub-section (1) of Section 127B of the Customs Act, 1962 include the duty assessed under Section 17 or Section 18 in respect of a bill of entry for warehousing as contingent liability or otherwise? What is the extent and scope of the said term? 2. Though the requirement in the application is disclosure of duty liability not already made before the proper officer, yet the said Section 127B of the Customs Act, 1962 does not specify the stage to be recognised i.e. whether the duty liability arising in course of assessment ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Special Bench. The Special Bench conducted its first sitting at Chennai on 12-3-2001 and 13-3-2001. S/Shri V.T. Gopalan, Additional Solicitor General (ASG), Chennai, Arvind Datar, Senior Advocate, Raghavan, Advocate, A.S. Sundarrajan, Advocate Consultant, V.S. Jayakumar, Income-tax Practitioner, Doiphode, Advocate and Ramesh, Advocate appeared and argued before the Bench. Shri M. Murugan, Deputy Commissioner, Customs House, Chennai appeared for the Revenue and made his submissions. Another sitting was held on 30-4-2001 at Mumbai, when S/Shri Sridharan, Advocate and M.H. Patil appeared and argued. S/Shri A.G. Kulkarni, C.A. and K.M. Mondal, Consultant filed their written submissions. 4.0 To briefly recapitulate the facts involved in the case covered by the application filed by M/s. Madras Petrochem Ltd., Chennai, they (M/s. Madras Petrochem Ltd.) had imported through Mumbai Port 400 MT of base Mineral Oil V-60. They filed warehousing Bill of Entry (BE for short) No. Imp./B000165, dated 5-3-1997 with Custom House, Mumbai. It was assessed provisionally on 6-3-1997 pending TR and discharge quantity. As per the Ullage Survey Report at the port of discharge, the quantity was 399.47 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... th April, 2001 were as under. 6.0 Shri V.T. Gopalan, Addl. Solicitor General, Chennai submitted that Section 127B(1) of the Customs Act does not make a distinction between absolute and contingent liabilities, as well as between an into-bond BE and ex-bond BE. Hence, there is no warrant to make a distinction between the two for examining the instant case. Therefore, if the difference of duty disclosed in the into-bond BE and disclosed in the application before the Settlement Commission is in excess of Rs. 2 lakhs, the application can be considered for admission subject to other conditions being satisfied. He also clarified that duty liability is fastened on the goods immediately on import and only the collection gets eclipsed by exemptions, if any. He also highlighted that the duty liability reflected on the into-bond BE and ex-bond BE would be the same, unless otherwise the duty rates have undergone a change since the time of filing the into-bond BE. He also canvassed that for purposes of Section 127B(1) officer competent to deal with the BE would be the proper officer . Relying on the decision of Supreme Court in the case of Commissioner of Income-tax (Calcutta) v. B.N. Bhattac ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ITSC provisions, for interpretation of Customs and Central Excise Settlement provisions. He pleaded that assessment under Section 17 on an into-bond BE is only for warehousing and hence tentative, whereas final assessment for collection of duty takes place only at the time of clearance for home consumption under Section 68. However, as the goods were removed clandestinely in the instant case, without filing an ex-bond BE for home consumption, assessment has not taken place and the original disclosure should be taken as nil. Disclosures in the form of admission in statements recorded during investigations are not relevant. Therefore, the disclosure made on the into-bond BE cannot be taken as a benchmark for comparison with liability disclosed before the Settlement Commission. As no disclosure was made at the time of removals, the entire disclosure made in the application before the Settlement Commission should be construed to be additional disclosure. However, he also conceded that the duty assessed on into- bond BE is not a contingent liability but only a provisional liability. 6.3 Shri B.S. Jayakumar, IT Practitioner, suggested that the Commission should adopt a broader perspect ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... is not a disclosure for the purpose of levy of duty, and specifically for the purpose of Section 127B. On the other hand, ex-bond Bill of Entry is filed for the purpose of payment of duty on the goods. Only in respect of the taxable event, an assessee is required to permit full and true disclosure. However, he also shared the view that assessment of the into-bond BE and duty indicated thereon cannot be termed as contingent liability, as a taxable event arises only in the event of filing of an ex-bond BE. He also submitted that since in the instant case the applicant had removed the goods from the warehouse without proper permission and discharge of duty, there was an attempt to evade and, therefore, for the purpose of Section 127B there has to be full and true disclosure of the modus operandi. It is this disclosure which would come within mischief of Section 127B. In regard to Section 68(c) proper officer would be, the Officer under whose custody the goods are warehoused. It is not correct to hold the officer assessing the into- bond BE at the time of warehousing as proper officer covered by Section 127B. In view of the fact that ex-bond BE was not filed in this case by the ap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... be looked into for interpreting statute. Accordingly, he relied on the contents of Form S.C.(C)-1 prescribed for applying to the Commission, wherein it is brought out that additional liability admitted should be out of that demanded in the SCN. In conclusion, the Counsel reiterated that the declaration of duty at into-bond BE stage is irrelevant and only that made on the ex-bond BE would be material. In view of the non-filing of ex-bond BE in this case, there was a NIL disclosure at the time of removal clandestinely from the warehouse. 6.8 Shri N.H. Patil, Advocate urged that the applicant could not have made a full and true disclosure of duty liability while presenting into-bond Bill of Entry. Hence, it will be only a contingent liability. Only the officer having jurisdiction over the warehouse would be the proper officer, and duty disclosed in the ex-bond BE will be the benchmark disclosure. Duty liability disclosed in the into-bond BE is a contingent liability. Since no ex-bond BE was filed in the instant case, the disclosure made in the application to the Commission is an additional disclosure. 6.9 Shri K.M. Mondal, Consultant also submitted in his written brief that assess ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rs to a taxable event and gets fastened on the goods immediately on their import, and warehousing only defers the moment of collection. Shri Raghavan, Advocate, categorized the assessment, on an into-bond BE as a provisional liability, while Shri Doiphode, advocate considered it a tentative liability. Shri Sridharan, Advocate pleaded that the question was irrelevant, in view of the fact that the declaration/disclosure in the into-bond BE is not the material benchmark for ascertaining the quantum of additional disclosure before the Commission. However, S/Shri Ramaesh and M.H. Patil advocates, answered in the affirmative, viz. that the duty disclosed on the into-bond BE is only a contingent liability. 7.3 Whether in case the reply to (1) above is in the negative, non-filing of ex-bond BE could be construed to mean nil disclosure and as such duty accepted as payable in column 12 of the application be taken as additional accepted liability for the purpose of clause (b) of the first proviso of sub-section (1) of Section 127B of the Customs Act, 1962. Arguments : ASG, Chennai had taken a view that the disclosure at into-bond BE stage itself is a benchmark for determining quantum of a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... carrying imported goods as also imported goods themselves are subject to various restrictions once they have entered the territorial borders of India. 9.1 Section 12 of the Customs Act provides that duties of Customs shall be levied at rates specified under the Customs Tariff Act, 1975 or any other law for the time being in force on goods imported into India or exported from India. In terms of Section 12, read with the definition of the term Import under Section 2(23) and definition of the term India under Section 2(27) of the Act; goods brought into the territorial waters of India from a place outside India become dutiable; though the quantification and the rate at which the duty would be chargeable is to be determined at the point of clearance of the goods for home consumption. This is so in view of the provisions of Section 15 of the Act. 9.2 It is in view of the aforesaid legal position that the provisions of Section 13 relating to duty on pilfered goods, Section 22 in respect of duty on damaged or deteriorated goods and Section 23 in respect of the duty on lost, destroyed or abandoned goods specifically provided for abatement or remission of duty otherwise leviable on ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... assessed the goods under Section 17. 9.5 The provisions of Section 68 and Section 15(1)(b) are applicable only when goods have been cleared from the warehouse within the permitted initial or permitted extended period as held by the Apex Court in Kesoram Rayon v. CC, Calcutta - 1996 (86) E.L.T. 464 (S.C.). These provisions have no relevance when the goods have been cleared from the warehouse improperly. 9.6 It would thus appear that the scheme of the Act contemplates assessment by a proper officer under Section 17 which is required to be modified so far as the rate of duty is concerned in terms of the provisions of Section 15(1)(b). 10.0 The Supreme Court s orders in the case of Union of India v. Apar Private Ltd. - 1999 (112) E.L.T. 3 (S.C.) and Kiran Spinning Mills v. Collector of Customs - 1999 (113) E.L.T. 753 (S.C.) deal with taxable events in the light of the provisions of Section 15(1)(b) of the Act. In short these judgments deal with the rate or amount of duty to be levied and not with the question of leviability or dutiability of the goods unde the charging Section i.e. Section 12 of the Act and assessement under Section 17 of the Act. 11.0 The provisions of law ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer; (b) the manner in which such duty liability incurred; and (c) the amount of additional duty accepted as payable. 12.1 The Legislature has employed the two phrases duty liability not disclosed to the proper officer and amount of additional duty accepted as payable and that too in the same Section/breath. Evidently, these two phrases are not synonymous. They do not refer to same thing, but refer to different things. Also, the latter expression refers to amount of duty . Therefore, evidently, the former expression as such, does not refer to amount of duty . If so, what do these words duty liability not disclosed before proper officer mean? What are the principles of interpretation to be adopted? 12.2 Duty liability not disclosed before the proper officer really refers to how the liability was attracted. It does not per se refer to the amount of duty liability in rupees and paise. It refers to liability to duty or how the liability arose. This is also reinforced from the expression manner in which such liability has been incurred employed in Section 127B after the first sentence. 12.3 Since, provisions of Chapter XIV are modelled on income-tax provis ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... erm duty liability means quantum of duty liable to be paid by the assessee or the liability of duty , is resolved by Form SC (C)-1. 13.2 The Form SC(C)-1 inserted by Notification No. 59/99-Cus. (N.T.) has been statutorily prescribed for making application to the Settlement Commission. Of the various particulars to be furnished to the Settlement Commission, the following are relevant for the present discussions : 1. Details of information which has not been correctly declared in the bill of entry/shipping bill. 2. Additional amount of duty payable on the goods covered in the Bill of Entry/Shipping Bill and the manner in which such duty has been derived. 3. Duty liability accepted out of the total duty demanded in the show cause notice, if any issued and the manner of such duty liability has been derived. 13.3 The above extract from the Form SC(C)-1 clearly show that duty liability mentioned in the first portion of Section 127B(1) does not refer to the amount of duty but the liability to duty and other requisite particulars as to how that liability arose. 13.4 In addition to these particulars, the assessee is also required to mention in the applic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... to emphasise that the policy of the law as disclosed in Chapter XIXA of the Income-tax Act is not to provide a rescue shelter for big tax dodgers who indulge in criminal activities by approaching the Settlement Commission and that the said Chapter is not meant for those who come after the event, i.e. after the discovery of the particulars of income and its source - or discovery of particulars of fraud perpetrated by the assessee, as the case may be - nor even to those who come to the Commission to forestall the investigation/inquiries which have reached a stage where the Department is in possession of material which though not sufficient to establish such concealment or fraud, is such that it is likely to establish it - may be some more material is required to establish it fully. We would like to mention, with respect, that the Hon ble Supreme Court was dealing with Section 245D(1) as it stood prior to 1-4-1979 in the earlier case whereas in the latter case the Hon ble Court was dealing with Section 245D(1A) as it stood during the period from 1-4-1979 to 26-9-1991. These provisions at the relevant time provided that an application shall not be proceeded with under this sub-se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2 lakhs over and above the amount demanded in the show cause notice. We are of the opinion that Section 127B of the Customs Act requires disclosure of duty liability which has not been disclosed before the proper officer and it has nothing to do with the liability as may be tentatively fixed in a show cause notice issued by the Department or the liability as may be unearthed by the Department as a result of their investigation. Under Section 127B what is required is that the application must contain a full and true disclosure of duty liability which has not been disclosed before proper officer and the manner in which such liability has been incurred and further that the additional amount of duty accepted as payable should exceed by Rs. 2 lakhs over and above what has been disclosed earlier by the applicant before a proper officer. The question of evasion unearthed by the Department is not relevant for this provision. Rather, since issue of a SCN is a precondition under clause (a) of the first proviso to sub-section (1) of Section 127B for an application to be filed with the Commission, it automatically presupposes an approach to Commission only after detection of the case, complet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... es of clause (b) of proviso to sub-section (1) of Section 127B of the Customs Act, 1962, keeping in view the evidence relied upon in the Show Cause Notice issued? In view of our reply to (I) above, the question does not arise. 18.0 The order constituting the Special Bench also requires us to decide on the question of Admission of the Settlement Application filed by M/s. Madras Petrochem Ltd., Chennai under Section 127B of the Customs Act, 1962 to settle the case in respect of the Show Cause Notice bearing F. No. SIIB/3/99/88/CAU-Chennai (SEA) Appg-8/2000, dated 16-3-2000 issued by the Commissioner of Customs, Chennai. It may be relevant to mention here that this Show Cause Notice, inter alia, demands Customs Duty of Rs. 26,17,287/- on the warehoused goods which are alleged to have been removed improperly and also requires the applicant to pay an interest amount of Rs. 3,07,885/-. As the applicant had already paid an amount, of Rs. 30 lakhs during the investigations of the case itself, the notice also proposes to adjust this amount against the duty and interest demanded. 18.1 The pending proceedings in this case are for levy and collection of duty as contained in the Show Caus ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... arrive at the total amount of duty leviable thereon. Further there is a letter dated 13-3-1997 from the applicant addressed to the Assistant Commissioner of Customs, Mumbai requesting for permission for bond-to-bond transfer of the goods in question to their factory premises at Chennai. There is a double duty bond executed by the applicant undertaking to observe all the provisions of the Customs Act and to pay all duties, rent, interest and charges claimable on account of the goods in question. The bill of entry in our view contains duty liability disclosed as required under Section 46 which has been assessed by a proper officer under Section 17 and any disclosure of additional duty liability as contemplated under Section 127B(1) has to be in addition to the liability disclosed in the bill of entry for warehousing filed under Section 46. 19.0 In view of our findings above, we hold that the application for Settlement of the case filed by M/s. Madras Petrochem Ltd. does not disclose any additional amount of duty accepted as payable compared to the disclosure made before a proper officer in the Bill of Entry filed for warehousing under Section 46. In fact the Annexure to the Applic ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... leading to the proposed demand. However, the said Notice itself cannot be considered to have been issued in relation to the BE for warehousing filed at Mumbai. Rather, the notice had been necessitated on account of contravention of the provisions of Section 72 of the Customs Act and consequent evasion of duty at Chennai, inasmuch as the bonded goods were not cleared in terms of procedure specified under Section 68 ibid, which includes filing of a BE for home consumption and obtaining orders for clearance from the proper officer at Chennai. 21.0 A view was presented by some of the Counsels/Consultants that the non-filing of BE for home consumption for clearance from the warehouse is a nil disclosure and hence the entire liability and duty accepted as payable in the application should be taken as additional admitted/accepted liability and duty. Reliance was also placed for the same on a decision of Supreme Court in the case of N.B. Sanjana, Assistant Collector of Central Excise, Bombay v. The Elphinstone Spinning Weaving Mills Co. Ltd. - [1978 (2) E.L.T. 399]. 21.1 The Bench observes that the facts involved in the case before Hon ble Supreme Court were that the Mills in questi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... disclosure. To this extent, reliance of the Counsels/Consultants to plea that because of the non-filing of BE before the proper officer in respect of warehoused goods at the time of their clearance for home consumption, the entire disclosure/duty accepted in the application before the Commission should be considered as additional disclosure/acceptance of duty is not acceptable. 22.0 Accordingly, having regard to the nature and circumstances of this case and after perusing the report of the Jurisdictional Commissioner submitted under Section 127C(1) and after considering the submissions made by both the sides before us, the Bench rejects the Application for Settlement dated 13-9-2000 filed by M/s. Madras Petrochem Ltd. 23.0 Judgment as per Gopinath Sarangi, Vice-Chairman, B.K. Bakshi and A.K. Mehta, Members. (I) With due respect though I agree with the conclusion in para 22 supra, that the application cannot be proceeded with, but I do not agree with the reasons advanced for coming to the said conclusion. This is because I find that the pleadings of the Learned Addl. Solicitor General and Learned Advocates and Consultants including the written submissions made, have not ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... hority in charge of the warehouse becomes the proper officer for levy, assessment and collection of customs duty thereon. The levy of duty of customs on imported goods vests on the proper officer in charge of the warehouse. The levy shifts from port of import to the warehouse. Thereafter the responsibility of assessment and collection, vests in the proper officer in charge of the warehouse. (b) It therefore follows, that once the imported goods are warehoused the taxable event is not extinguished. In other words, for imported warehoused goods the taxable event is shifted from place of importation to the place of warehousing. Had it not been so, Section 68 ibid. would not have provided for clearance of warehoused goods for home consumption and Section 72 ibid. about penalty for goods improperly removed from the warehouse? The assessment made in the into-bond bill of entry at the port of importation, execution of warehousing bond with reference to duty assessed in such bill of entry, recovery of duty as assessed in case of loss before warehousing etc. are a prior action till the issue of certificate of warehousing and in the nature of safeguarding interest of revenue with reference ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e the impugned orders and remand the matters to the Collector of Customs (Appeals) for considering the appeals on the question of merits. Original documents if any filed by the appellants may be returned to the appellants after an application and observance of all the formalities. (b) The Tribunal has further examined the provisions of Sections 46, 47 and 59 of the Customs Act, 1962 in the case of Ficom Organic Ltd. v. Commissioner of Central Excise, Mumbai III [1997 (94) E.L.T. 639] and have concluded as below : The Tribunal held that the assessment at Bombay was only for the purpose of knowing the amount of duty so that a bond twice the amount to be executed by the importer under Section 59 of the Customs Act. Since no duty was paid at Bombay, there was no clearance under Section 47 of the Customs Act at that place. The effective clearances took place only at Ludhiana. We also refer to a decision by this Bench in this context in the case of Dipen Enterprises v. Collector reported in 1990 (49) E.L.T. 481. In that case it was argued that reassessment at the place of ex-bond clearance would amount to review of the earlier into-bond assessment. The Bench held that n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rest, penalties, rent and other charges. Duty chargeable is at the rate applicable on the date of their deemed removal from the warehouse i.e. the date on which the permitted initial or extended period expired. Again in the case of Khattar Enterprises (P) Ltd. v. Collector of Customs, Calcutta [1997 (94) E.L.T. 454 (S.C.)], the Hon ble Supreme Court was considering the case where the warehousing bill of entry was substituted for the home consumption bill of entry in relation to import of wood and articles of wood. It may be mentioned that partial exemption from duty was withdrawn. The Supreme Court has held that once the substitution is allowed then substituted bill of entry has to be treated as operating and the rate of duty applicable shall be the rate of duty on the date on which substituted bill of entry was presented. IV (e) There are certain decisions relating to the application of rate of duty of the goods cleared from the warehouse. The Court have analysed the provisions under Section 12, Section 15, Section 46, Section 31 and Section 68 of the Customs Act, 1962 and have concluded that duty has to be paid with reference to relevant date as per Section 15 of the Custo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (V) (b) This proposition assumes importance in view of provisions under Chapter IX of the Customs Act, 1962. Chapter IX of the Customs Act, 1962 has a self-contained code for warehousing imported goods. Section 64 of the Act, provides enhanced right to the owner to deal with the warehoused goods and Section 65 provides for manufacture of other operations in relation to goods in a warehouse. When the goods are subjected to manufacture or any other operations, such imported goods may or may not undergo transformation. Whether such goods undergoes transformation, is to be reclassified. The officer in charge of the warehouse is competent to do so. Similarly, the officer in charge of the warehoused goods can re-classify the goods if he finds that classification done in the warehousing Bills of Entry is not proper on the basis of records before him. Thus the right of the officer incharge of the warehouse is not only confined to charging correct rate of duty as is prevalent on the date of clearance but also to ensure proper assessment and payment of duty thereof. (V) (c) Karnataka High Court in the case of Devilog Systems v. Commissioner of Customs, Bangalore [1995 (76) E.L.T. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... cer in charge of the warehouse has also exercised a similar function. With reference to duty of excise where the goods are manufactured and stored in the bonded storeroom pending clearance thereon, the Supreme Court in the case of Wallace Flour Mills v. Collector - [1989 (44) E.L.T. 598 (S.C.)] has observed as below : The taxable event is the manufacture. But the liability to pay the duty is postponed till the time of removal under Rule 9A of the said Rules. In this connection, reference may be made to the decision of the Karnataka High Court in Karnataka Cement Pipe Factory v. Supdt. of Central Excise [1986 (23) E.L.T. 313] where it was decided that the words as being subject to a duty of excise appearing in Section 2(d) of the Act are only descriptive of the goods and not to the actual levy. Excisable goods , it was held, do not become non-excisable goods merely by the reason of the exemption given under the notification. This view was also taken by the Madras High Court in Tamil Nadu (Madras State) Handloom Weavers Co-operative Society Ltd. v. Assistant Collector of Central Excise [1978 (2) E.L.T. (J57)]. On the basis of Rule 9A of the said Rules, the Central Excise author ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... goods are merely warehoused. The import duty will be levied at the rate and on the basis of the valuation determined in accordance with the provisions prevailing on the date of clearance from the warehouse for which purpose the importer has to file a fresh bill of entry for home consumption. In other words, it is the date of filing the bill of entry for home consumption which determines the rate of duty in clauses (a) and (b) of Section 15. Inasmuch as the matter is left to the option of the importer and also because a uniform principle is adopted by the Act. As explained above, we see no room for any legitimate grievance of discrimination. (VI) (e) In this connection, I may refer to decisions of Hon ble Madhya Pradesh High Court in the case of Wainganga Club v. Commissioner of Sales Tax Madhya Pradesh [1971 (27) STC 542]. Though this is a case not in relation to warehoused goods but refers to liability to pay tax. As discussed supra taxable event is defined with reference to the liability to pay duty. The liability to pay duty occurs out of act of commission or omission; the High Court has referred to various decisions of the Supreme Court and has concluded that unless there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion etc. so as to arrive at correct levy, assessment and collection of duty due thereon. (VIII) From the decisions referred to supra, and also analysis of the statutory provisions, the following legal position emerges : 1. Taxable event is distinct and different from assessment. 2. Taxable event continues till the mass of imported goods goes for consumption. 3. The documentation at the port of import gets extinguished on receipt of imported goods to the warehouse and receipt of warehousing certificate by the port of origin. 4. The proper officer, in charge of the warehouse has to assess the imported goods to customs duty on receipt of home consumption bill of entry filed under Section 68 of the Customs Act, 1962. 5. The assessment at serial 4 supra includes re-assessment and consequentially all aspect of assessment such as classification, valuation etc. has to be examined by the said proper officer. 6. Removal from the warehouse without filing home consumption bill of entry is deemed to be unauthorised clearance amounting to smuggling. 7. After issue of warehousing certificate and receipt thereof by the officer incharge of port of entry, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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