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TMI Blog2023 (10) TMI 904X X X X Extracts X X X X X X X X Extracts X X X X ..... , the petitioner cannot be declared as the beneficial owner of the smuggled goods within the meaning of Section 2(3A) of the Customs Act, 1962. Unless, the petitioner himself imported the goods and exercised effective control over the smuggled imported goods, the petitioner cannot be called as the beneficial owner . Therefore, while it cannot be construed that the impugned Order-in-Original was passed without a proper authorization from an officer senior in rank to the officer who has passed the impugned Order-in-Original, the petitioner cannot be treated as a beneficial owner of the smuggled goods. The case is remitted back to the respondent to re-do the exercise for imposing penalty on the petitioner in proportion with the role played by the petitioner in the alleged attempt to smuggle 2,01,13,000 pieces of sewing machine needles of various sizes of Brand Organ and Flying Tiger and 70,200 pieces of measuring tapes of various sizes - Petition disposed off. - Honourable Mr. Justice C. Saravanan For the Petitioner : Mrs.L.Maithili For the Respondent : Mr.H.Siddharth Junior Standing Counsel ORDER The petitioner has challenged the impugned Order ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nalty of Rs. 45,00,000/- (Rupees Forty Five Lakhs) on M/s. Saran Enterprises under Section 112 of the Customs Act, 1962, for rendering the goods liable for confiscation or abetting the same by their omissions or commissions. 8. Considering the involvement and gravity of offence, I impose a penalty of Rs. 5,00,000/- (Rupees Five Lakhs) on M/s. Asian Shipping Agencies, Customs Broker under Section 112 of the Customs Act, 1962, for rendering the goods liable for confiscation or abetting the same by their omissions or commissions. 9. Considering the involvement and gravity of offence, I impose a penalty of Rs. 50,00,000/- (Rupees Fifty Lakhs only) on Shri. C.Solomon Selraraj under Section 114AA of the Customs Act, 1962 for causing to submit false documents or submitting false documents to Customs. 10. I am refraining from taking action on demand of duty or imposition of penalty against the Noticees who are not traceable by the Investigating Authorities and against whom they have reserved the right of the department to investigate afresh about the role of those persons in smuggling of undeclared goods, as and when fresh lead or evidences surface and upon issue of supplementary ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ails,required for filing Bill of Entry to be handed over to Shri. Salomen Selvaraj through Shri. Manikandan and those documents are false, Shri. Vishal is liable for penalty under Section 112 of the Customs Act, 1962 and 114AA of the Customs Act. 1962. (vi). As Shri. Salomen Selvaraj could not give any details about Shri Vishal and Shri Sunil Saran and as Shri Salomen Selvaraj had effective control over the imported goods under reference, thereby becoming a beneficiary of the import. (vii). Shri. Salomen Selvaraj approached M/s. Asian Shipping Agencies, Customs Broker through Shri K. Faizullah,Clerk, M/s. Asian Shipping Agencies for filing Bill of Entry and Shri K. Faizullah filed the self-assessed Bill of Entry No.4228874 dated 01.12.2017 for the shipment imported vide container TEMU 6929879 based on the documents given by Shri. Salomen Selvaraj, in the name of M/s. R.M. Enterprises and the said act of Shri. Salomen Selvaraj amounts to abetment to smuggling attempt of Shri. Vishal attracting penalty under Section 112 of the Customs Act, 1962 and and 114AA of the Customs Act, 1962. (viii). RMS picked up the self-assessed Bill of Entry No.4228874 dated 01.12.2017 for verifi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Ax1 model sewing machine needles are meant for household type sewing machines. (xiv). The detained goods were seized vide seizure memorandum dt. 29.12.2017 and were handed over to the Custodian, CFS for safe custody. (xv). The declared premises and the residential address of the IEC of M/s. R.M. Enterprises were found to be fictitious upon verification (xvi). Shri. K.Faizullah and Shri. Prem Kumar, Partner, M/s.Asian Shipping Agencies, the Customs Broker admitted Shri.Salomen Selvaraj engaged them to file the Bill of Entry under reference and had taken care of duty payment, examination etc., (xvii). Shri. R. Chandrakumar admitted that he had attended the examination work at the CFS for the Bill of Entry under reference. (xviii). Shri. Salomen Selvaraj admitted that he had undertaken to clear the goods under reference on lump sum basis including transportation charges despite knowing that the container under reference had sewing machine needles and measuring tapes concealed inside and further admitted that he undertaken this work at the behest of Shri. Vishal whose whereabouts are unknown to him. (xix). Searches conducted at premises of M/s. Sunny International, Ko ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Crore Twenty Nine Lakh Seventy Two Thousand Four Hundred and Sixteen Only) on the undeclared measuring tapes and the undeclared sewing machine needles found in the imported consignment as given in the Annexure- III is liable to be demanded under Section 28(4) of the Customs Act, 1962 read with Section 46(4) of the Customs Act, 1962. (xxvii). The total Anti-Dumping Duty leviable of Rs. 3,26,27,958/- (Rupees Three Crore Twenty Six Lakh Twenty Seven Thousand Nine Hundred and Fifty Eight Only) on the undeclared measuring tapes and the undeclared sewing machine needles found in the imported consignment in terms of the Notification 31/2015-Cus(ADD) dt. 09.07.2015 and Notification 31/2017-Cus (ADD) dt. 22.06.2017 respectively as given in the Annexure-III is liable to be demanded under Section 28(4) of the Customs Act, 1962 read with Section 46(4) of the Customs Act, 1962. (xxviii). Interest on the differential duty leviable is also to be demanded under Section 28AA of the Customs Act, 1962. (xxix). The undeclared goods with a total value of Rs. 3,99,16,875/- (Rupees Three Crore Ninety Nine Lakh Sixteen Thousand Eight Hundred and Seventy Five Only) and duly seized are liable for ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... M Enterprises, Shri. Vishal and Shri. Saloman Selvaraj are all appear to be importers for the purpose of this smuggling attempt read with Section 2(26) of the Customs Act, 1962. 29. In view of the above, M/s. R.M Enterprises, S/Shri C.Saloman Selvaraj, Shri. Vishal, Shri. Sunil Saran, M/s. Saran Enterprises and M/s. Asian Shipping Agencies, Customs Broker jointly and severally are hereby called upon to show cause to the Commissioner of Customs, Commissionerate- II, Custom House,No. 60, Rajaji Salai, Chennai-1 within 30 days from the date of receipt of this show cause notice as to why: a) The undeclared goods totally valued at Rs. 3,99,16,875/-(Rupees Three Crore Ninety Nine Lakh Sixteen Thousand Eight Hundred and Seventy Five Only) duly seized, imported vide container No. TEMU 6929879 and Bill of Entry No.4228874 dated 01.12.2017, attempted to be smuggled should not be confiscated under section 113(d), 111(f), 111(l) and 111(m) of the Customs Act, 1962 read with Section 19 of the Legal Metrology Act, 2009 read with Section 2(w) ibid. b) The declared goods of Rs. 4,27,122/- (Rupees Four Lakh Twenty Seven Thousand One Hundred and Twenty Two Only)based on reassessed value, du ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... unt of duty or interest under Sub-Section (8) to Section 28 of the Customs Act, 1962, within a period of one year from the date of Show Cause Notice or within further period of one year as per the Proviso to Section 28 (9) (b) of the Customs Act, 1962. 8. It is submitted that as per second Proviso to Section 28 (9) of the Customs Act, 1962, where the proper officer fails to determine the amount of duty within such extended period, such proceedings shall be deemed to have been concluded as if no notice had been issued. 9. It is submitted that one year period would have expired on 17.06.2019. It is submitted that even if there was an extension of time, the period would have at best expired on 16.06.2020. However, the impugned Order-in-Original No.76206/2020 has been passed on 28.09.2020 by taking advantage of Section 6 of the Taxation and other Laws (Relaxation of Certain Provisions), Ordinance, 2020, which is impermissible. 10. It is therefore submitted that the impugned Order-in-Original No.76206/2020 dated 28.09.2020 is non-est in law apart from the fact that the impugned order also suffers from gross violation of principles of natural justice as none of the relied upon d ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ined that the Ramesh Menon and the firm R.M.Enterprises were fictitious with bogus address. 15. It is submitted that in the meantime, two letters dated 20.12.2017 were received by DRI from an unknown person representing himself to be the authorized signatory of importer M/s.R.M. Enterprises stating that he is admitted in hospital and that he will meet the DRI Officer after discharge from the hospital. It is pertinent to state that though the letter head had a reference to the registered Nellore Address of the importer at Nellore, the address on the postal envelope of the sender was mentioned as 42, Anna Street, Chennai. The said address was once again verified by DRI and was found to be bogus. All efforts to trace the importer Ramesh Menon did not yield any results. 16. It is submitted that since Ramesh Menon could not be traced, M/s. Asian Shipping Agencies who was the Customs Broker on record for the Bill of Entry No. 4228874 dated 01.12.2017 was called upon to give their statement under Section 108 of the Customs Act. The partner of M/s. Asian Shipping Agencies namely Mr. Prem Kumar had appeared on 09.01.2018 and gave his voluntary statement under section 108 of the Custom ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of importer M/s RM Enterprises through one Mr. Manikandan for customs clearance c. On receipt of documents, he had submitted the same to M/s.Asian Shipping Agencies for filing Bill of Entry d. That one Mr. Manikandan had given a sum of Rs. 10,00,000 for meeting all the expenses for clearing the consignment and that he neither knew Manikandan's address and phone numbers e. That he had orgainsed two consignments for M/s RM Enterprises, Amar Exports and Sidhu Naturals for all of which he had received the import documents from the said Vishal 20. It is pertinent to state that when asked about the details of Mr Vishal and Mr. Manikandan, the Petitioner did not co operate during investigation and did not reveal any details about them. The petitioner had paid the customs duty and abetted the smuggling of undeclared goods by following up all activities of clearance of goods. He was arrested on 11.01.2018 by DRI and remanded to judicial custody. 21. It is submitted that thereafter one Mr. R Chandra kumar an employee of the Petitioner was called upon to give his voluntary statement. In his statement Mr. Chandra kumar had stated that a. His job was to assist the Petition ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... but the same proved to be an exercise in futility. 29. It is further submitted that a detailed investigation was also carried by the DRI and the Respondent and based on the same the Petitioner's role in relation to the smuggled goods came into light. 30. It is submitted that the submission of the petitioner that a period of 2 years had lapsed from the date of Show Cause Notice and as such the time period to pass the adjudication order had expired in terms of Section 28(8) and 28(9)(b) is legally unsustainable. 31. It is submitted that in the present instance, the Show Cause Notice demanding duty under Section 28 (4) of the Customs Act, 1962 was issued to the Petitioner on 18.06.2018. Since there were no proper replies received from the various noticees and due to their non appearance for the personal hearing, the adjudication process could not be completed within a period of one year as envisaged under Section 28(4) of the Customs Act. 32. It is pertinent to state that since the adjudication process could not be completed within the period stipulated under Section 28 (4) of the Customs Act, 1962, the Principal Chief Commissioner of Customs had invoked the provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed a partial relief. However, the order was not placed before the Commissioner. In any event, this can be done by the petitioner by filing an appeal as against the impugned order. 36. By way of written submissions, learned counsel for the petitioner submitted that the Show Cause Notice dated 18.06.2018 bearing Reference F.No.DRI/CZU/VIII/48/ENQ-1/INT-50/2017 has lapsed as the impugned Order-in-Original No.76206/2020 dated 28.09.2020 was passed beyond the prescribed period and extended time limit as per Section 28(9)(b) of the Customs Act, 1962. 37. It is further submitted that the extension granted under Section 6 of The Taxation and Other Laws (Relaxation and Amendment of Certain Provisions) Ordinance, 2020 is applicable only to the time limit specified under the ordinance and not to the extended time limit. 38. It is submitted that in terms of second proviso to Section 28(9) of the Customs Act, 1962, the proceedings shall be deemed to have concluded as if no notice had been issued, where the adjudication order has not been passed within the stipulated time limit. 39. It is submitted that the Show Cause Notice dated 18.06.2018 bearing Reference F.No.DRI/CZU/VIII/48/E ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... o-notices to answer to the Show Cause Notice to the Commissioner of Customs, Commissionerate-II, Custom House, No.60, Rajaji Salai, Chennai 600 001, who is the proper officer to pass the order within the extended period. The petitioner has given an interim reply on 15.10.2018. 49. The Commissioner of Customs, Commissionerate-II was thus the proper officer who was required to pass the order within the extended period of limitation prescribed under first proviso to Section 28(9)(b) of the Customs Act, 1962. 50. Section 28 of the Customs Act, 1962 was amended vide Finance Act, 2018. On the date of issuance of Show Cause Notice, the amended Section 28(9) of the Customs Act, 1962 was in force. Prior to amendment and after amendment Section 28(9) of the Customs Act, 1962, reads as under:- Before amendment After amendment Section 28(9) - The proper officer shall determine the amount of duty or interest under sub-section (8), - a) within six months from the date of notice in respect of cases falling under clause (a) of subsection (1); (b) within one year from the date of notice in respect of cases falling u ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tion (8) to Section 28 of the Customs Act, 1962. 56. If the proper officer fails to determine the amount or interest Sub-Section (8) to Section 28 of the Customs Act, 1962, within such extended period, the show cause proceeding issue shall be deemed to have concluded as if no notice had been issued. 57. Thus, the period specified in Section 28(9)(a) or (b) of the Customs Act, 1962 as the case may be could be extended by a senior officer in rank to the proper officer for a period of six months or one year as the case may be, if the proper officer was prevented from determining the amount, duty or interest within the period specified therein. 58. To decide whether the period was extended for completing the show cause for determining the duty within the limitation prescribed under Section 28(9) of the Customs Act, 1962, the originals of the files were called for and examined. 59. Facts on record indicates that the relied upon documents were sought by the petitioner vide letter dated 15.10.2018. The relied upon documents were sent to the petitioner after obtaining permission of the Commissioner-VIII along with notice dated 19.11.2018. 60. Although, in the original file ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... eply, the petitioner has stated that the imposition of penalty proposed under Section 114AA of the Customs Act, 1962 cannot be countenanced as the petitioner merely forwarded the documents received 'as such' from Shri.Vishal, Shri.Manikandan, Shri.Sunil Saran and Shri.Ramesh Menon.R. 68. The initial period of one year would have expired for passing the impugned Order-in-Original No.76206/2020 dated 28.09.2020, expired on 17.06.2019. The extended period under proviso to Section 28(9) of the Customs Act, 1962 expired on 16.06.2020. 69. Meanwhile, lockdown was imposed from 24.03.2020 due to outbreak of Covid-19 pandemic. It is during the interregnum, the Principal Commissioner of Customs has given the approval for passing the order on 26.06.2020 by 30.09.2020. 70. The reason given in the file was that Show Cause proceedings could not be adjudicated within a period of one year from the date of issuance of the notice. The permission to pass order within the further period of one year was issued to the proper officer by the Principal Commissioner of Customs. Thus, the respondent has passed the impugned Order-in-Original No.76206/2020 dated 28.09.2020. 71. Thus, there ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... compliance of such action has not been made within such time, stand extended to the 30th day of June, 2020 or such other date after the 30th day of June, 2020 as the Central Government may, by notification, specify in this behalf: Provided that the Central Government may specify different dates for completion or compliance of different actions under clause (a) or clause (b). 77. The time limit specified in or prescribed or notified under the Acts viz., Central Excise Act, 1944, the Customs Act, 1962 (except sections 30, 30A, 41 , 41A, 46 and 47), the Customs Tariff Act, 1975 and Chapter V of the Finance Act, 1994, which fell during the period between 20.03.2020 and 29.06.2020 or such other date after 29.06.2020 stood extended upto 30.06.2020. 78. The Central Government by a notification, could also extend the period for the completion or compliance of such action to such other date after 30.06.2020. 79. Thus, the period was initially extended upto 30.06.2020. By a Notification such date could be extended after 30.06.2020 as the Central Government may in the Notification specify in that behalf as is required. 80. Section 6 of Chapter-V of the ordinance was extende ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Customs Act, 1962 (52 of 1962) (except sections 30, 30A, 41, 41A, 46 and 47), the Customs Tariff Act, 1975 (51 of 1975) or Chapter V of the Finance Act, 1994 (32 of 1994) falls for the completion or compliance of such action as specified under clause (a) or (b) of the said section; and (ii) the 30th day of September, 2020 shall be the end date to which the time limit for completion or compliance of such action shall stand extended. 82. Thus, there was a special dispersion under the Ordinance, Act and the above Notification. The decision of the Hon'ble Supreme Court in Assam Urban Water Supply and Sewerage Board Vs. Subash Projects and Marketing Limited , (2012) 2 SCC 624, rendered in the context of proviso to Section 34(3) of the Arbitration and Conciliation Act, 1996 cannot be imported in the context of orders to be passed under Customs Act, 1962 or Central Excise Act, 1944 or Finance Act, 1994 or any of the Act specified in the said Ordinance and Act. 83. The Hon'ble Supreme Court in Assam Urban Water Supply and Sewerage Board Vs. Subash Projects and Marketing Limited , (2012) 2 SCC 624 had interpreted Sections 4 and 2(j) of the Limitation Act, 1963 and Se ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Marketing Limited , (2012) 2 SCC 624. It was held as under:- 14. Section 2(j) of the 1963 Act defines: 2.(j).'period of limitation' which means the period of limitation prescribed for any suit, appeal or application by the Schedule, and 'prescribed period' means the period of limitation computed in accordance with the provisions of this Act . Section 2(j) of the 1963 Act when read in the context of Section 34(3) of the 1996 Act, it becomes amply clear that the prescribed period for making an application for setting aside arbitral award is three months. The period of 30 days mentioned in proviso that follows sub-section (3) of Section 34 of the 1996 Act is not the 'period of limitation' and, therefore, not 'prescribed period' for the purposes of making the application for setting aside the arbitral award. The period of 30 days beyond three months which the court may extend on sufficient cause being shown under the proviso appended to sub-section (3) of Section 34 of the 1996 Act being not the 'period of limitation' or, in other words, 'prescribed period', in our opinion, Section 4 of the 1963 Act is not, at all, at ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rcise of power under Article 142 read with 141 of the Constitution of India. 93. The Hon'ble Supreme Court in in Sagufa Ahmed and others Vs. Upper Assam Polywood Products Private Limited and others , (2021) 2 SCC 317 concluded that the appellant therein could not take advantage of the aforesaid order dated 23.03.2020, as the extended period of limitation had already expired on 02.02.2020. 94. The Hon'ble Supreme Court followed its earlier views in Assam Urban Water Supply and Sewerage Board Vs. Subash Projects and Marketing Limited , (2012) 2 SCC 624, referred to supra . In paragraph Nos.22 23 of Sagufa Ahmed and others Vs. Upper Assam Polywood Products Private Limited and others , (2021) 2 SCC 317, the Larger Bench of the Hon'ble Supreme Court held as under:- 22. The words prescribed period appear in several Sections of the Limitation Act, 1963. Though these words prescribed period are not defined in Section 2 of the Limitation Act, 1963, the expression is used throughout, only to denote the period of limitation. We may see a few examples: (i) Section 3(1) makes every proceeding filed after the prescribed period , liable to be dismissed, subj ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... on-est and is liable to be declared as a nullity under Section 28(9) of the Customs Act, 1962 cannot be countenanced and is therefore liable to be rejected. 100. Therefore, the preliminary issue regarding the jurisdiction of the respondent to pass the impugned order in the light of the decision of the Hon'ble Supreme Court in Assam Urban Water Supply and Sewerage Board Vs. Subash Projects and Marketing Limited , (2012) 2 SCC 624 and Sagufa Ahmed and others Vs. Upper Assam Polywood Products Private Limited and others , (2021) 2 SCC 317 are answered in the negative and therefore against the petitioner. I shall therefore now deal with the other contentions raised by the learned counsel for the petitioner and the learned Junior Standing Counsel for respondent. 101. The petitioner has been treated as a beneficial owner of the imported goods in view of Section 2(26) read with 2(3A) of the Customs Act, 1962. 102. It has been concluded that the petitioner Shri.C.Solomon Selvaraj, Proprietor of M/s. The Sea Shipping Forwarders is the beneficial owner as Shri.RameshMenon.R, Proprietor of M/s.R.M.Enterprises and other persons namely Shri.Vishal, Shri.Manikandan, Shri.Sunil ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of such duty. 108. The petitioner has acted as a conduit for Shri Vishal and one Shri Sunil Saran and perhaps Shri.RameshMenon.R, the Proprietor of M/s.R.M.Enterprises. The petitioner had merely engaged services of the Customs Broker viz., M/s.Asian Shipping Agencies through one K.Faizullah, the clerk of the said Customs Broker for filing Bill of Entry No.4228874 dated 01.12.2017 for clearance of the container based on the documents that were furnished by the petitioner. Role of the Customs Broker M/s.Asian Shipping Agencies is also required to be probed and if there was any complexity, appropriate penalty has to be imposed on it. 109. The petitioner appears to have admitted that he had undertaken to clear the goods under reference on lump sum basis including transportation charges despite knowing that the container under reference had sewing machine needles and measuring tapes concealed inside and further admitted that he undertaken this work at the behest of Shri.Vishal whose whereabouts were not known to him. 110. The petitioner also has an history of indulging in smuggling and was earlier arrested. Perhaps, for the same reason, service of the petitioner was engaged fo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 116. Consignment of needles and measuring tapes were attempted to be smuggled. A reading of the Show Cause Notice dated 18.06.2018 bearing Reference F.No.DRI/CZU/VIII/48/ENQ-1/INT-50/2017 and the impugned Order-in-Original No.76206/2020 dated 28.09.2020 indicates that the petitioner played a small role in the attempt of the importer to smuggle the consignments of needles by filing Bill of Entry using the name and Import Export Code of the importer viz., M/s.R.M.Enterprises. 117. A further reading of the impugned Order-in-Original No.76206/2020 dated 28.09.2020 and the Show Cause Notice dated 18.06.2018 bearing Reference F.No.DRI/CZU/VIII/48/ENQ-1/INT- 50/2017, indicates that the petitioner is a petty offender who facilitated the above mentioned persons who remain behind the shrouds for clearance and smuggling of undeclared goods viz., needles and measuring tapes with a view to evade customs duty and anti-dumping duty, etc,. 118. In the Bill of Lading, names of other parties would have been there. Strangely, the respondents have failed to name them and implicate them in the Show Cause Notice dated 18.06.2018. That apart, Import Export Code is not granted by the Director Gene ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... marketing or dealing in the smuggled goods. Therefore, the petitioner cannot be declared as the beneficial owner of the smuggled goods within the meaning of Section 2(3A) of the Customs Act, 1962. Unless, the petitioner himself imported the goods and exercised effective control over the smuggled imported goods, the petitioner cannot be called as the beneficial owner . 125. Therefore, while it cannot be construed that the impugned Order-in-Original No.76206/2020 dated 28.09.2020 was passed without a proper authorization from an officer senior in rank to the officer who has passed the impugned Order-in-Original No.76206/2020 dated 28.09.2020, the petitioner cannot be treated as a beneficial owner of the smuggled goods. 126. In view of the above discussion, the impugned Order-in- Original No.76206/2020 dated 28.09.2020 is liable to be set aside and the case is remitted back to the respondent to re-do the exercise for imposing penalty on the petitioner in proportion with the role played by the petitioner in the alleged attempt to smuggle 2,01,13,000 pieces of sewing machine needles of various sizes of Brand Organ and Flying Tiger and 70,200 pieces of measuring tapes o ..... X X X X Extracts X X X X X X X X Extracts X X X X
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