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1.
2. Custom Duty
3. Judiciary
ORDER OF HIGHER APPELLATE AUTHORITY SHOULD BE FOLLOWED UNRESERVEDLY BY
SUBORDINATE AUTHORITIES
* POONAM GANDHI
* | Custom Duty - Judiciary
|
* Download PDF
* 07 Apr 2023
* 1,341 Views
* 0 comment
CASE LAW DETAILS
Case Name : Commissioner of Customs (Import) Vs Siya Paper Mart Pvt. Ltd.
(CESTAT Delhi)
Appeal Number : Customs Appeal No. 52190 of 2018
Date of Judgement/Order : 23/03/2023
Related Assessment Year :
Courts : All CESTAT CESTAT Delhi
Download Judgment/Order
COMMISSIONER OF CUSTOMS (IMPORT) VS SIYA PAPER MART PVT. LTD. (CESTAT DELHI)
CESTAT Delhi held that the principles of judicial discipline require that the
orders of the higher appellate authorities should be followed unreservedly by
the subordinate authorities.
Facts- Notification no. 102/2007-Cus dated 14.09.2007 has been issued to provide
for refund of the SAD if the importer sells the imported goods and pays the VAT
on them. The benefit of this notification is available subject to some
conditions including condition in paragraph 2(c) of the notification that „the
importer shall file a claim for refund of the said additional duty of customs
paid on the imported goods with the jurisdictional customs officer before the
expiry of one year from the date of the payment of the said additional duty of
customs’.
The respondent filed a refund claim which was rejected by the Assistant
Commissioner for the reasons that the claim was filed beyond one year from the
date of payment of duty and hence were time-barred as per condition 2(c) of the
notification.
However, the Commissioner (A) allowed the appeals of the respondent relying on
the judgment of the jurisdictional Delhi High Court in M/s. Sony India Pvt. Ltd.
vs Commissioner of Customs, New Delhi in which the it was held that the
notification must be read down insofar as it places the restriction of one year
for filing the refund claim.
Revenue filed these appeals on the ground that in another case of Wilhem
Textiles India Pvt. Ltd., involving the same issue, Revenue’s appeal to Delhi
High Court on the same issue was dismissed and Revenue’s SLP against the
dismissal by the Delhi High Court has been admitted by the Supreme Court.
Therefore, according the Revenue, Commissioner (Appeals) has erred in observing
the judicial discipline and following the ratio of the judgment of the
jurisdictional High Court and should have defied Delhi High Court while passing
the impugned order.
Conclusion- The law relating to the judicial discipline was explained in
clearest terms by the Supreme Court in UNION OF INDIA vs. KAMLAKSHI FINANCE
CORPORATION LTD. It was held that the principles of judicial discipline require
that the orders of the higher appellate authorities should be followed
unreservedly by the subordinate authorities. The mere fact that the order of the
appellate authority is not “acceptable” to the department – in itself an
objectionable phrase – and is the subject-matter of an appeal can furnish no
ground for not following it unless its operation has been suspended by a
competent Court. If this healthy rule is not followed, the result will only be
undue harassment to assessees and chaos in administration of tax laws.
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FULL TEXT OF THE CESTAT DELHI ORDER
Revenue filed these two appeals on the same issue in respect of the same
respondent and hence they are being disposed of together. Goods which are
imported into India are chargeable to basic customs duty, additional duty of
customs and also Special Additional duty of Customs1levied under Section 3(5) of
the Customs Tariff Act, 1975 on some goods. SAD is levied @ 4% ad valorem in
order to provide a level playing field to domestic industry because goods
manufactured in India have to pay Value Added Tax (VAT) but imported goods do
not have to pay it because sale in the course of international trade is not
exigible to VAT by the State Governments. After importing the goods, if the
importer uses the goods, he has to suffer the 4% SAD so paid. However, if the
importer sells the goods to someone else, then that transaction takes place
within India and is chargeable to VAT at the hands of the State Government.
2. Notification No. 102/2007-Cus dated 14.9.2007 has been issued to provide for
refund of the SAD if the importer sells the imported goods and pays the VAT on
them. The benefit of this notification is available subject to some conditions
including condition in paragraph 2(c) of the notification that „the importer
shall file a claim for refund of the said additional duty of customs paid on the
imported goods with the jurisdictional customs officer before the expiry of one
year from the date of the payment of the said additional duty of customs’.
3. In appeal no. C/52190/2018, the respondent filed a claim for refund of Rs.
2,10,632/- of which the Assistant Commissioner rejected refund of Rs. 1,53,507/-
for the reason that the claims were filed beyond one year from the date of
payment of duty and hence were time-barred as per condition 2 (c) of the
notification.
4. In appeal no. C/52192/2018, the respondent filed a claim for refund of Rs.
22,631/- which the Assistant Commissioner rejected for the reason that the claim
was filed beyond one year from the date of payment of duty and hence was
time-barred as per condition 2 (c) of the notification.
5. The Commissioner (Appeals), by the impugned orders, allowed appeals of the
respondent relying on the judgment of the jurisdictional Delhi High Court in
M/s. Sony India Pvt. Ltd. vs Commissioner of Customs, New Delhi² in which the it
was held that the notification must be read down insofar as it places the
restriction of one year for filing the refund claim. The relevant paragraphs of
this decision are as follows:
14. The expression “so far as may be” in this context, under Section 27 is
significant as well as instructive. The levy under Section 3(5) is conditional
upon the Central Government‟s opinion that it is necessary to “counter-balance
the sales tax, value added lax, local lax or any other charges for the time
being leviable on a like article.”; the rate of duty – where more than one levy
exists, would be the highest of such rates and the terms of imposition of SADC
would be spelt out in the notification. In this case, the regime existing before
the notification of 2008 did not specify any period of limitation – and perhaps
advisedly so. Some customs authorities apparently started applying Section 27,
drawing inspiration from Section 3(8) which led to confusion. In Notification
No. 102/2007-Cus., dated 14-9-2007 there was no period of limitation; by
Circular No. 6/2008-Cus., an amending notification providing for one year period
from the date of payment of the additional duty of customs was issued, through
Notification No. 93/2008-Cus., dated, 1-8-2008, amending Para 2(c) of the 2007
Notification. The net effect of these was that a one year period was insisted
upon for refund applications. That period was calculable from date of payment of
duty (SAD) : Dr. Partap Singh & Anr. v. Director of Enforcement, Foreign
Exchange Regulation Act & Ors., 1985 (3) SCC 72 is an authority for the
proposition that the use of the phrase “so far as may be” in a later statute,
with reference to provisions in an earlier statute, means that the provisions of
the referred (earlier) statute are to be followed “to the extent possible”. The
Supreme Court, in that case turned down the argument that the letter and content
of Section 165 of the Code of Criminal Procedure was to be followed in Foreign
Exchange Regulation Act proceedings, by virtue of Section 37(2) of that Act. It
was held, crucially that:
“The submission that Section 165(1) has been incorporated by pen and ink in
Section 37(2) has to be negatived in view of the positive language employed in
the section that the provisions relating to searches shall so far as may be
apply to searches under Section 37(1). If Section 165(1) was to be incorporated
by pen and ink as sub-section (2) of Section 37, the legislative draftsmanship
will leave no room for doubt by providing that the provisions of the CrPC
relating to searches shall apply to the searches directed or ordered under
Section 37(1) except that the power will be exercised by the Director of
Enforcement or other officer exercising his power and he will be substituted in
place of the Magistrate. The provisions of sub-section (2) of Section 37 has not
been cast in any such language. It merely provides that the search may he
carried out according to the method prescribed in Section 165(1).”
16. Section 27(1) of the Customs Act prescribes a time limit of expiry of “one
year, from the date of payment of such duty or interest…”. Section 27(1B) lists
out three contingencies when the one year limit applies with modified effect.
That provision has the effect of shifting the date from which the refund claim
is to be reckoned. All that can be inferred from the term “so far as may be”
would be that specific provisions relating to the mechanism applicable for
refund, in the Customs Act, applied; not the period of limitation. The Customs
authorities had never understood Section 27(1) as to mean that a one year period
of limitation was applicable. Audioplus (supra) and United Chemicals Industries
(supra) are both testimony to this. It is the circulars/notifications of 2008
and No. 16/2009 which for the first time harped on the one year period of
limitation. Circular No 6/2008, dated 28-4-2008 issued by the C.B.E. & C. stated
that :
Time-Limit: “4.
In “4.1 the Notification No. 102/2007-Cus., dated 14-9-2007, no specific
time-limit has been prescribed for filing a refund application. Under the
circumstances, a doubt has been expressed that whether the normal time-limit of
six months prescribed in Section 27 of the Customs Act, would apply. In the
absence of specific provision of Section 27 being made applicable in the said
notification, the time-limit prescribed in this section would not be
automatically applicable to refunds under the notification. Further, it was also
represented that the goods imported may have to be dispatched for sale to
different parts of the country and that the importer may find it difficult to
dispose of the imported goods and complete the requisite documentation within
the normal period of six months. Taking into account various factors, it has
been decided to permit importers to file claims under the above exemption upto a
period of one year from the date of payment of duty. Necessary change in the
notification is being made so as to incorporate a specific provision prescribing
maximum time-limit of one year from the date of payment of duty, within which
the refund could be filed by any person. It is also clarified that the importers
would be entitled to refund of duties only in respect of quantities for which
the prescribed documents are made available and the claims submitted within the
maximum prescribed time of one year. Unsold stocks would not be eligible for
refunds.”
Notification No. 93/2008, dated 1-8-2008 was issued prescribing the period of
limitation as one year from the date of payment of additional duty of Customs.
17. Plainly, therefore. Section 27 was understood as not applying to SAD cases,
even though it was in the statute book for many years. Yet, with the
introduction of the circular and then the notification (No. 93), the Customs
authorities started insisting that such limitation period which was prescribed
with effect from 1-8-2008 (by notification) became applicable. There is a body
of law that essential legislative policy aspects (period of limitation being one
such aspect) cannot be formulated or prescribed by subordinate legislation.
Khemka and Co. (Agencies) Private Ltd. v. State of Maharashtra, (1975) 35 STC
571 and other decisions are authority on the question that in matters which deal
with substantive rights, such as imposition of penalties and other provisions
that adversely affect statutory rights, the parent enactment must clearly impose
such obligations; subordinate legislation or rules cannot prevail or be made, in
such cases. The imposition of a period of limitation for the first time, without
statutory amendment, through a notification, therefore could not prevail.
18. For these reasons, this Court holds that the amending notification must be
read down to the extent that it imposes a limitation period. The question of law
framed is therefore, answered in favour of the assessee and against the Revenue.
The appeal accordingly succeeds and is allowed without any order as to costs.
6. Revenue‟s SLP against the above judgment was dismissed by the Supreme Court
in view of the limitation leaving the question of law open3. On the same
question of law, Bombay High Court held that the limitation of one year applies
for refunds in CMS INFOSYSTEMS LTD. Versus UNION OF INDIA4. Appeal against CMS
Infosystems5 is admitted and is pending before Supreme Court. Thus, the binding
legal precedent as far as Delhi jurisdiction is concerned is Sony India which
still holds the field.
7. Revenue filed these appeals on the ground that in another case of Wilhem
Textiles India Pvt. Ltd., involving the same issue, Revenue‟s appeal to Delhi
High Court on the same issue was dismissed and Revenue‟s SLP against the
dismissal by the Delhi High Court has been admitted by the Supreme Court.
Therefore, according the Revenue, Commissioner (Appeals) has erred in observing
the judicial discipline and following the ratio of the judgment of the
jurisdictional High Court and should have defied Delhi High Court while passing
the impugned order. The relevant portion of the appeal signed by the Committee
of the two Commissioners on page 18 of the appeal reads as follows:
“22. Since, the issue remains that the question of law has not been decided
till date and is open, the learned Commissioner (Appeals) has erred in ignoring
the legal position as laid down vide notification no. 93/2008 and deciding the
matter against the revenue. Hence, this appeal.”
8. We are surprised as to how the Committee of two Commissioners has not only
concluded that the Commissioner (Appeals) does not have to follow judicial
discipline but have gone further to say that the Commissioner (Appeals) has
erred in following the binding precedent of the jurisdictional High Court. The
prayer before us is to hold that the Commissioner (Appeals) erred in following
judicial discipline and that he should have not followed the binding precedent
of the jurisdictional High Court because in some other case, on the same issue
in which also the High Court dismissed the Revenue‟s appeal, an SLP has been
admitted by the Supreme Court. The submissions of Revenue in this appeal that
the Commissioner (Appeals) should have not followed the binding ruling of the
jurisdictional High Court can only result in considerable harassment to the
assessee-public through needless litigation without any benefit to the Revenue.
The law relating to the judicial discipline was explained in clearest terms by
the Supreme Court in UNION OF INDIA vs. KAMLAKSHI FINANCE CORPORATION LTD6
“5. The learned Additional Solicitor General, however, submits that the learned
Judges have erred in passing severe strictures against the two Assistant
Collectors who had dealt with the matter. He submitted that these officers had
given reasons for classifying the goods under Heading 39.19 and not 85.46 and
could do no more. He submitted that they acted bona fide in the interests of
Revenue in not accepting a claim which, they felt, was not tenable.
6. Sri Reddy is perhaps right in saying that the officers were not actuated by
any mala fides in passing the impugned orders. They perhaps genuinely felt that
the claim of the assessee was not tenable and that, if it was accepted, the
Revenue would suffer. But what Sri Reddy overlooks is that we are not concerned
here with the correctness or otherwise of their conclusion or of any factual
mala fides but with the fact that the officers, in reaching their conclusion,
by-passed two appellate orders in regard to the same issue which were placed
before them, one of the Collector (Appeals) and the other of the Tribunal. The
High Court has, in our view, rightly criticised this conduct of the Assistant
Collectors and the harassment to the assessee caused by the failure of these
officers to give effect to the orders of authorities higher to them in the
appellate hierarchy. It cannot be too vehemently emphasised that it is of utmost
importance that, in disposing of the quasi-judicial issues before them, revenue
officers are bound by the decisions of the appellate authorities. The order of
the Appellate Collector is binding on the Assistant Collectors working within
his jurisdiction and the order of the Tribunal is binding upon the Assistant
Collectors and the Appellate Collectors who function under the jurisdiction of
the Tribunal. The principles of judicial discipline require that the orders of
the higher appellate authorities should be followed unreservedly by the
subordinate authorities. The mere fact that the order of the appellate authority
is not “acceptable” to the department – in itself an objectionable phrase – and
is the subject-matter of an appeal can furnish no ground for not following it
unless its operation has been suspended by a competent Court. If this healthy
rule is not followed, the result will only be undue harassment to assessees and
chaos in administration of tax laws.
7. The impression or anxiety of the Assistant Collector that, if he accepted the
assessee‟s contention, the department would lose revenue and would also have no
remedy to have the matter rectified is also incorrect. Section 35E confers
adequate powers on the department in this regard. Under sub-section (1), where
the Central Board of Excise and Customs [Direct Taxes] comes across any order
passed by the Collector of Central Excise with the legality or propriety of
which it is not satisfied, it can direct the Collector to apply to the Appellate
Tribunal for the determination of such points arising out of the decision or
order as may be specified by the Board in its order. Under sub-section (2) the
Collector of Central Excise, when he comes across any order passed by an
authority subordinate to him, if not satisfied with its legality or propriety,
may direct such authority to apply to the Collector (Appeals) for the
determination of such points arising out of the decision or order as may be
specified by the Collector of Central Excise in his order and there is a further
right of appeal to the department. The position now, therefore, is that, if any
order passed by an Assistant Collector or Collector is adverse to the interests
of the Revenue, the immediately higher administrative authority has the power to
have the matter satisfactorily resolved by taking up the issue to the Appellate
Collector or the Appellate Tribunal as the case may be. In the light of these
amended provisions, there can be no justification for any Assistant Collector or
Collector refusing to follow the order of the Appellate Collector or the
Appellate Tribunal, as the case may be, even where he may have some reservations
on its correctness. He has to follow the order of the higher appellate
authority. This may instantly cause some prejudice to the Revenue but the remedy
is also in the hands of the same officer. He has only to bring the matter to the
notice of the Board or the Collector so as to enable appropriate proceedings
being taken under S. 35E(1) or (2) to keep the interests of the department
alive. If the officer’s view is the correct one, it will no doubt be finally
upheld and the Revenue will get the duty, though after some delay which such
procedure would entail.
8. We have dealt with this aspect at some length, because it has been suggested
by the learned Additional Solicitor General that the observations made by the
High Court, have been harsh on the officers. It is clear that the observations
of the High Court, seemingly vehement, and apparently unpalatable to the
Revenue, are only intended to curb a tendency in revenue matters which, if
allowed to become widespread, could result in considerable harassment to the
assessee-public without any benefit to the Revenue. We would like to say that
the department should take these observations in the proper spirit. The
observations of the High Court should be kept in mind in future and utmost
regard should be paid by the adjudicating authorities and the appellate
authorities to the requirements of judicial discipline and the need for giving
effect to the orders of the higher appellate authorities which are binding on
them.
9. With the above observations, this Special Leave Petition is dismissed.
9. In view of the above, we dismiss both these appeals filed by the Revenue and
uphold the impugned orders.
Note:-
1. SAD
2. 2014(304)ELT 660 (Del.)
3. Commissioner v. Sony India Pvt. Ltd. – 2016 (337) E.L.T. A102 (S.C.)]
4. 2017 (349) E.L.T. 236 (Bom.)
5. CMS Info Systems Ltd. v. Union of India – 2018 (360) E.L.T. A190 (S.C.)]
6. 1991 (55) E.L.T. 433 (S.C.)
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