Case Law Details
Patanjali Foods Ltd. Vs Union of India (Bombay High Court)
In a significant legal development, the Bombay High Court recently ruled on a dispute involving Patanjali Foods Ltd. and the Union of India concerning the reassessment of customs duty on imported crude palm oil. The case centered on the applicability of revised tariff values after the goods were cleared under Section 68 of the Customs Act, 1962.
Patanjali Foods imported crude palm oil in bulk from Just Oil & Grain Pte. Ltd., Singapore, under multiple contracts in early 2021. The imports were covered by Warehouse Bills of Entry and subsequently Ex-Bond Bills of Entry for home consumption, all filed before a tariff value revision via Notification No. 47/2021-Customs (N.T.) dated May 13, 2021.
The dispute arose when customs authorities sought to reassess duty based on the revised tariff value of USD 1219 per Metric Tone (PMT), up from USD 1163 PMT. Patanjali Foods argued that since their bills of entry were presented and assessed under the previous tariff value, the higher rate should not apply retroactively.
The High Court examined Section 15 of the Customs Act, which stipulates that the rate of duty applicable is determined by the date and time of bill of entry presentation. Citing the Supreme Court’s ruling in Union of India & Ors. vs. M/s G.S. Chatha Rice Mills & Anr., the court reaffirmed that self-assessment based on prevailing rates at the time of entry is legally binding.
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