Dr. A.K. Jayasankaran Nambiar, J.
2. Customs Appeal No.2 of 2025 is preferred by the assessee
whereas Customs Appeal No.5 of 2024 is preferred by the Revenue.
Accordingly, fish protein obtained by decalcification of fish scales were
imported from countries like China and Japan. From around April,
2016 however, imports were also made of the same product from
countries like Indonesia. It is significant to state that the imports in
question were made under cover of advance authorizations that were
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obtained by the assessee from the Directorate General of Foreign Trade
[DGFT] under the scheme of advance authorization introduced by the
Government of India to encourage and promote exports from India.
The advance authorization scheme enables duty free import of
inputs/raw materials required for manufacture of export goods. The
application for an advance authorization is to be made to the DGFT, and
after verification of the details of export products, details of imported
items required for the manufacture of export products, the
manufacturing process and the details of indigenous items required for
manufacture of export products, the DGFT issues the advanced
authorization specifying the description of items permitted for imports,
quantity thereof and description of goods required to be exported and
quantity thereof.
3. It is the case of the assessee that the item referred to as
'decalcified fish scale for collagen' is a rich source of the particular
protein that is required for the purposes of manufacture of collagen
peptides which are then exported by the assessee. It would appear that
while the initial imports effected by the assessee classified the input as
'fish protein' for the purposes of the advance authorization scheme,
during an inspection of the goods imported vide Bill of Entry
No.5034927 dated 25.04.2016, it was found that the imported products
were tagged in polypropylene bags having the marks 'decalcified fish
scale for collagen (fish protein)'. The Revenue, therefore, after
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2025:KER:45956
investigation and testing of the goods, found that the declaration of the
goods as 'fish protein' was incorrect as the goods were found to be
processed/de-mineralized fish scale classifiable under Customs Tariff
Heading 0511 9190. The Revenue also found on investigation that
about 57 shipments valued at approximately Rs.27 Crores had been
imported from suppliers located in various countries like Japan, China
etc. over a period of nearly five years, and that the suppliers therein
had described the imported goods as 'fish protein'.
4. A show cause notice was therefore issued to the assessee for
mis-declaring the goods. The show cause notice was issued in respect
of 51 consignments, 42 of which pertained to past imports effected by
the assessee and 9 of which pertained to the live transactions that were
provisionally assessed by the Customs Department. In the adjudication
proceedings that followed, the Commissioner of Customs classified the
imported products under Chapter heading 0511 9190 and demanded a
differential duty, notwithstanding that the goods imported were
covered under the advance authorization scheme. It was the case of
the Department that the benefit of the concessional rate of duty under
Notification No.96/2009 dated 11.09.2009, which was applicable for
import of goods under advance authorization scheme, was not available
to the assessee since he had allegedly mis-declared the imported
product as 'fish protein' when the correct description ought to have
been 'decalcified fish scale'. Apart from the demand of differential duty
& :: 6 ::
2025:KER:45956
computed by the Commissioner, the goods were also directed to be
confiscated on account of the suppression of the correct description of
the goods and for misdeclaring the same. The confiscated goods were
however allowed to be redeemed on payment of redemption fine, and
penalties under Sections 112(a), 114A and 114AA of the Customs Act,
1962 were also imposed on the assessee.
5. In the appeal preferred by the assessee before the Appellate
Tribunal, the Appellate Tribunal framed the following issues for
consideration:
(i) Whether the imported item is fish protein as declared by the
appellant or is it processed/demineralised fish scales at as per
the test reports ?
(ii) Whether the product is to be classified under chapter heading
0511 9190 based on the description is demineralised fish scales
allowed to be classified under chapter heading 3504 0099 as
claimed by the appellant ?
(iii) Whether the appellant had mis-declared the description of the
product in order to claim the benefit of advance authorization ?
(iv) Whether the appellant had made any willful mis-declaration of
the description of the goods which attracted invocation of extended
period under the provisions of the Customs Act, 1962 which
warranted imposition of various penalties ?
Thereafter, after hearing the assessee as also the Revenue in the
matter, the Appellate Tribunal concluded that the imported goods were
correctly classifiable as 'decalcified fish scale' under Custom Tariff
Heading 0511 9190 and not as 'protein' under Custom Tariff Heading
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2025:KER:45956
3504 0099. The Tribunal found that although decalcified fish scale may
be a rich source of the protein required for manufacture of collagen
peptide, what was imported was not the protein itself. The Tribunal
however found that in as much as the consignments that were imported
in the past were under cover of advance authorizations that mentioned
the imported product as 'fish protein' and what was shown in the
records as imported was actually 'fish protein', their findings with
regard to mis-classification could not be made applicable to the past
transactions. The demand of differential duty was therefore sustained
only in respect of the live transactions covered by 9 consignments/Bills
of Entry that were under provisional assessment. In relation to the
past imports therefore, the Appellate Tribunal set aside the demand for
differential duty as also the imposition of redemption fine and penalty.
As regards the 9 consignments/Bills of Entry that were under
provisional assessment and pertained to live transactions, the Appellate
Tribunal found that the differential duty demanded in respect of those
Bills of Entry could be sustained although the question of redemption
fine and penalty did not arise since the assessments themselves were
only provisional in nature.
6. As already noticed, the Revenue is in appeal before us
aggrieved by the setting aside of the differential duty demand,
redemption fine and penalty in respect of the past consignments
imported by the assessee, whereas the assessee in appeal before us
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2025:KER:45956
aggrieved by the confirmation of the differential duty demand in
respect of the live transactions. As regards the latter appeal, it is
submitted before us by the learned senior counsel Sri.V.Sridharan
appearing on behalf of the assesee that, insofar as the live transactions
are concerned, the assessee had paid the differential duty under
protest and cleared the goods, and the limited issue to be considered
now is with regard to the finding of the Tribunal regarding the
necessity for payment of differential duty.
7. We have heard Sri.V.Sridharan, the learned senior counsel
assisted by Sri.Dhananjay Sethuraj, the learned counsel appearing on
behalf of the assessee and Sri.R.Harishankar, the learned Standing
Counsel appearing on behalf of the Revenue.
8. On a consideration of the rival submissions, we find that the
question that essentially arises for consideration is whether, on the
facts of the instant case, a mis-description of the inputs imported under
cover of an advance authorization is really relevant for the purposes of
levy and collection of import duty under the Customs Act read with the
Customs Tariff Act. It is significant that under the Foreign Trade
(Development and Regulation) Act, the issuance of advance
authorization and monitoring of the imports effected under cover of
such advance authorization is within the regulatory jurisdiction of the
DGFT. In the instant case, the authorities entrusted with the
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2025:KER:45956
administration of the advance authorization scheme do not have a case
that there was a breach of any of the conditions of the advance
authorization issued to the assessee. That apart, we note from the
provisions of the Foreign Trade Policy, 2009 to 2014 issued by the
Central Government under Section 4 of the Foreign Trade
(Development and Regulation) Act, that the object of the advance
authorization scheme is only to ensure that what is imported is an input
that is used for the manufacture of a final product that is exported. We
also find that the import of items under Chapter 5 and Chapter 35, to
the extent relevant for the instant cases, are both restricted in terms of
the Foreign Trade Policy, and the limited condition under which
products under the said Chapters can be imported is that they have to
be covered by an advance authorization granted by the Central
Government. It is not in dispute in the instant case that the advance
authorization was in fact granted to the assessee, and under cover of
the same, the assessee had imported the very same item albeit under
different names for many years. For the period between 2012 and
2016, the very same product was imported as 'fish protein' whereas it
is only in respect of 9 Bills of Entry filed thereafter that the item
imported was shown as 'decalcified fish scale'. The Revenue does not
have a contention that the items imported earlier and now were, in any
manner different, except for the differential description of the same in
the import documents. It is presumably by noting that the item
imported was the same that the authorities under the advance
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2025:KER:45956
authorization scheme did not view the imports of the same goods under
a different name as a breach by the assessee of any of the conditions of
the advance authorization granted to them. We also note that under
the advance authorization scheme, whether the goods are classifiable
under Chapter 5 or Chapter 35, they are liable to only a nil rate of duty
so long as they are covered by the advance authorization scheme.
9. It is against the backdrop of the above factual position that we
need to consider the case of the Revenue that the assessee was not
entitled to the benefit of the Notification No.96/2009 dated 11.09.2009
that granted the benefit of nil rate of duty in respect of inputs imported
under the advance authorization scheme. In view of the discussion
above, we have to hold that in as much as the classification of the
imported items had no bearing on the legality of imports for the
purposes of the advance authorization scheme, and the authorities
entrusted with the administration of the said scheme have not viewed
the different descriptions used by the assessee at the time of import of
the product under the advance authorization scheme to be in breach of
the terms and conditions of the advance authorization, the stand of the
Revenue that the assessee would lose the benefit of the notification in
question, cannot be accepted. It is relevant in this connection to notice
the judgment of the Supreme Court in Titan Medical Systems Pvt.
Ltd. v. Collector of Customs, New Delhi - [2003 (151) E.L.T. 254
(SC)] where in almost identical circumstances, where the customs
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2025:KER:45956
authorities had demanded a differential duty alleging a
mis-representation of facts to the licensing authority, the Supreme
Court, while rejecting the said contention, found as follows:
"As regards the contention that the appellants were not entitled to the
benefit of the exemption notification as they had misrepresented to the
licensing authority, it was fairly admitted that there was no requirement,
for issuance of a licence, that an applicant set out the quantity or value of
the indigenous components which would be used in the manufacture.
Undoubtedly, while applying for a licence, the appellants set out the
components they would use and their value. However, the value was only
an estimate. It is not the respondents' case that the components were
not used. The only case is that the value which had been indicated in the
application was very large whereas what was actually spent was a paltry
amount. To be noted that the licensing authority having taken no steps
to cancel the licence. The licensing authority have not claimed that there
was any misrepresentation. Once an advance licence was issued and not
questioned by the licensing authority, the Customs authorities cannot
refuse exemption on an allegation that there was misrepresentation. If
there was any misrepresentation, it was for the licensing authority to
take steps in that behalf."
10. We also find that in view of the fact that it is not in dispute
that the assessee has been importing the same product during the
previous transactions covered by 42 Bills of Entry [in respect of which,
the Tribunal had set aside the demand of differential duty] and the
subsequent transactions covered by 9 Bills of entry [which are under
provisional assessment], there is no justification for demanding a
differential duty payment for the latter transactions alone. We are also
told at the time of hearing by the learned senior counsel
Sri.V.Sridharan that during the period subsequent to the period
covered by the show cause notice, the assessee has obtained advance
authorization for importing the same product this time under the
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2025:KER:45956
nomenclature 'decalcified fish scale' and no objection has been taken
by the Revenue to such import.
We are of the view that the imports effected by the assessee had
to be seen as covered by the notification aforementioned that permitted
an import at nil rate of duty so long as the goods were imported in
terms of the advance authorization scheme. In the absence of any
objection by the licensing authority or cancellation of the advance
authorization, the Department could not have denied the benefit of the
notification to the assessee. We therefore allow Customs Appeal No.2
of 2025 preferred by the assessee and dismiss Customs Appeal No.5 of
2024 preferred by the Revenue.
Sd/-
DR. A.K.JAYASANKARAN NAMBIAR
JUDGE
Sd/-
P.M.MANOJ
JUDGE
prp/
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2025:KER:45956
APPENDIX OF CUS. APPEAL.NO.2/2025
PETITIONER'S ANNEXURES:
Annexure A1 TRUE COPY OF LETTER DATED 15.07.2024
Annexure A2 TRUE COPY OF GENERAL RULES OF INTERPRETATION
OF FIRST SCHEDULE TO CUSTOMS TARIFF ACT,
Annexure A3 TRUE COPY OF CHAPTER 05 OF CUSTOMS TARIFF
ACT, 1975
Annexure A4 TRUE COPY OF CHAPTER 35 OF CUSTOMS TARIFF
ACT, 1975
Annexure A5 TRUE COPY OF HSN EXPLANATORY NOTES TO
CHAPTER 5
Annexure A6 TRUE COPY OF HSN EXPLANATORY NOTES TO
CHAPTER 35
Annexure A7 TRUE COPY OF PARA 4.1.13 FROM FOREIGN TRADE
POLICY 2009-14
Annexure A8 TRUE COPY OF PARA 4.1.13 FROM FOREIGN TRADE
POLICY 2009-14 AS AMENDED BY ANNUAL
SUPPLEMENT OF 2012 W.E.F. 05.06.2012
Annexure A9 TRUE COPY OF CIRCULAR NO. 54 (RE-2008)/2004-
2009 DATED 09.01.2009
Annexure A10 TRUE COPY OF RELEVANT PORTION RELATING TO
DUTY EXEMPTION — SCHEME OF FOREIGN
TRADE POLICY 2009-2014
Annexure A10(a) TRUE COPY OF HANDBOOK OF PROCEDURE 2009-2014
Annexure A11 TRUE COPY OF CUSTOMS NOTIFICATION NO.
96/2009-CUS. DATED 11.09.2009 ISSUED UNDER
SECTION 25 OF CUSTOMS ACT, 1962 WHICH GRANTS
EXEMPTION TO MATERIALS IMPORTED INTO INDIA
AGAINST ADVANCE AUTHORIZATION IN TERMS OF
PARA 4.1.3 OF THE FOREIGN TRADE POLICY 2009-
Annexure A12 TRUE COPY OF CUSTOMS NOTIFICATION NO.
18/2015-CUS. DATED 01.04.2015 ISSUED QUA
FOREIGN TRADE POLICY 2015-2020
Annexure A13 TRUE COPY OF CUSTOMS NOTIFICATION NO.
21/2023-CUS. DATED 01.04.2023 ISSUED QUA
FOREIGN TRADE POLICY 2023
& :: 14 ::
2025:KER:45956
Annexure A14 TRUE COPY OF GENERAL LICENSING NOTES —
ITC (HS) 1997-2002, MAY 2000 EDITION
Annexure A15 TRUE COPY OF GENERAL LICENSING NOTES —
ITC (HS) 2009-2014, 19TH EDITION
Annexure A16 TRUE COPY OF CHAPTER 05 — ITC (HS)
2009-2014, 19TH EDITION
Annexure A17 TRUE COPY OF CHAPTER 35 — ITC (HS)
2009-2014, 19TH EDITION
Annexure A18 TRUE COPY OF THE LIVESTOCK IMPORTATION ACT,
Annexure A19 TRUE COPY OF THE LIVE-STOCK IMPORTATION
(AMENDMENT) ORDINANCE, 2001
Annexure A20 TRUE COPY OF NOTIFICATION S.O. 655 (E) DATED
07.07.2001
Annexure A21 TRUE COPY OF NOTIFICATION S.O. 1043 (E)
DATED 16.10.2001
Annexure A22 TRUE COPY OF NOTIFICATION S.O. 2666 (E)
DATED 16.10.2014
Annexure A23 TRUE COPY OF NOTIFICATION S.O. 3112 (E)
DATED 30.09.2016
Annexure A24 TRUE COPY OF OPINION FROM TRADE TRACK DATED
31.05.2010
Annexure A25 TRUE COPY OF OFFER SHEET OF THE SELLER DATED
08.04.2011
Annexure A25(a) TRUE COPY OF PURCHASE ORDER DATED 09.04.2011
Annexure A25(b) TRUE COPY OF COMMERCIAL INVOICE DATED
26.04.2011 ISSUED BY THE SELLER
Annexure A25(c) TRUE COPY OF PACKING LIST DATED 26.04.2011
Annexure A25(d) TRUE COPY OF CERTIFICATE OF ANALYSIS
Annexure A25(e) TRUE COPY OF BILL OF ENTRY DATED 07.05.2011
Annexure A26 TRUE COPY OF BILL OF ENTRY NO.7867111 DATED
06.09.2012
Annexure A26(a) TRUE COPY OF INVOICE ISSUED BY THE SUPPLIER
DATED 20.08.2012
Annexure A27 TRUE COPY OF HEALTH CERTIFICATE DATED
27.09.2010 ISSUED BY COUNTRY OF ORIGIN
Annexure A28 TRUE COPY OF TEST REPORT OF CENTRAL
INSTITUTE OF FISHERIES TECHNOLOGY DATED
20.09.2012 QUA THE SAMPLE DRAWN BY CUSTOMS
FOR THEIR TESTING BILL OF ENTRY NO. 7867111
DATED 06.09.2012
Annexure A29 TRUE COPY OF BILL OF ENTRY NO.5581063 DATED
10.06.2016 FOR IMPORT MADE IN JUNE 2016
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2025:KER:45956
— AFTER THE REQUIREMENT OF OBTAINING
SANITARY IMPORT PERMIT
Annexure A29(a) TRUE COPY OF INVOICE ISSUED BY THE SUPPLIER
DATED 24.05.2016 FOR IMPORT MADE IN JUNE
2016 — AFTER THE REQUIREMENT OF
OBTAINING SANITARY IMPORT PERMIT
Annexure A29(b) TRUE COPY OF HEALTH CERTIFICATE DATED
28.04.2016 FOR IMPORT MADE IN JUNE 2016
— AFTER THE REQUIREMENT OF OBTAINING
SANITARY IMPORT PERMIT
Annexure A29(c) TRUE COPY OF PURCHASE ORDER DATED 15.04.2016
FOR IMPORT MADE IN JUNE 2016
Annexure A30 TRUE COPY OF SANITARY IMPORT PERMIT DATED
04.08.2016 ISSUED BY THE DEPARTMENT OF
ANIMAL HUSBANDRY, DAIRYING AND FISHERIES
HAVING VALIDITY OF 6 MONTHS
Annexure A31 TRUE COPY OF SANITARY IMPORT PERMIT DATED
07.12.2016 ISSUED BY THE DEPARTMENT OF
ANIMAL HUSBANDRY, DAIRYING AND FISHERIES
HAVING VALIDITY OF 6 MONTHS
Annexure A32 TRUE COPY OF SANITARY IMPORT PERMIT DATED
26.07.2018 ISSUED BY THE DEPARTMENT OF
ANIMAL HUSBANDRY, DAIRYING AND FISHERIES
Annexure A33 TRUE COPY OF NORMS APPLICATION DATED
17.11.2012 ALONG WITH RELEVANT ANNEXURES
INCLUDING TECHNICAL WRITE UP
Annexure A34 TRUE COPY OF NORMS DATED 27.09.2013 FIXED BY
DGFT
Annexure A35 TRUE COPY OF NORMS APPLICATION DATED
27.02.2020 ALONG WITH RELEVANT ANNEXURES
INCLUDING TECHNICAL WRITE UP
Annexure A36 TRUE COPY OF NORMS FIXED BY DGFT DATED
06.10.2022
Annexure A37 TRUE COPY OF APPLICATION DATED 04.05.2012
FILED BEFORE THE DGFT FOR ADVANCE
AUTHORIZATION WITH RELEVANT ENCLOSURES
INCLUDING TECHNICAL WRITE-UP OF THE PRODUCT
Annexure A37(a) TRUE COPY OF ADVANCE AUTHORIZATION NO.
1010049774 DATED 01.06.2012 ISSUED BY DGFT
Annexure A38 TRUE COPY OF RELEVANT PORTION OF APPLICATION
DATED 16.01.2015 OF THE APPELLANT FOR GRANT
OF ADVANCE AUTHORIZATION
Annexure A38(a) TRUE COPY OF ADVANCE AUTHORIZATION NO.
1010059005 DATED 05.02.2015 GRANTED BY DGFT
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2025:KER:45956
Annexure A39 TRUE COPY OF APPLICATION DATED 16.10.2019
FILED BEFORE DGFT IN OCTOBER 2019 FOR
ADVANCE AUTHORIZATION ALONG WITH RELEVANT
ENCLOSURES
Annexure A39(a) TRUE COPY OF ADVANCE AUTHORIZATION NO.
1010060321 DATED 06.11.2019 ISSUED BY DGFT
Annexure A40 TRUE COPY OF BILL OF ENTRY NO. 6451300 DATED
13.01.2020 FOR IMPORT MADE IN JANUARY 2020
UNDER ADVANCE AUTHORIZATION
Annexure A40(a) TRUE COPY OF INVOICE ISSUED BY THE SUPPLIER
DATED 08.01.2020 FOR IMPORT MADE IN JANUARY
2020 UNDER ADVANCE AUTHORIZATION
Annexure A40(b) TRUE COPY OF PURCHASE ORDER DATED 06.12.2019
FOR IMPORT MADE IN JANUARY 2020 UNDER
ADVANCE AUTHORIZATION
Annexure A40(c) TRUE COPY OF HEALTH CERTIFICATE DATED
12.12.2019 FOR IMPORT MADE IN JANUARY 2020
UNDER ADVANCE AUTHORIZATION
Annexure A40(d) TRUE COPY OF PACKING LIST DATED 25.12.2019
FOR IMPORT MADE IN JANUARY 2020 UNDER
ADVANCE AUTHORIZATION
Annexure A40(e) TRUE COPY OF BILL OF LADING NO.155900071170
DATED 17.12.2019 FOR IMPORT MADE IN JANUARY
2020 UNDER ADVANCE AUTHORIZATION
Annexure A40f TRUE COPY OF CERTIFICATE OF ORIGIN DATED
17.12.2019 FOR IMPORT MADE IN JANUARY 2020
UNDER ADVANCE AUTHORIZATION
Annexure A40(g) TRUE COPY OF CERTIFICATE OF ANALYSIS FOR
IMPORT MADE IN JANUARY 2020 UNDER ADVANCE
AUTHORIZATION
Annexure A41 TRUE COPY OF EXPERT OPINION BY MR. M.D.
NAIR, PH.D, FNAE, STATING THAT THE
TERMINOLOGY (FISH PROTEIN) USED BY THE
APPELLANT FOR THE PRODUCT WAS CORRECT
Annexure A42 TRUE COPY OF APPEAL MEMORANDUM FILED BEFORE
CESTAT BY APPELLANT
Annexure A43 TRUE COPY OF WRITTEN SUBMISSION FILED BEFORE
CESTAT DATED 27.10.2023 BY APPELLANT
Annexure A44 TRUE COPY OF RELEVANT EXTRACT OF THE ARTICLE
TITLED "TILAPIA (OREOCHROMIS AUREUS)
COLLAGEN FOR MEDICAL BIOMATERIALS" AUTHORED
BY DAVID R. VALENZUELA AND OTHERS DATED
03.04.2018
Annexure A45 TRUE COPY OF RELEVANT EXTRACT FROM ARTICLE
TITLED "ISOLATION AND CHARACTERIZATION OF
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2025:KER:45956
FISH SCALE COLLAGEN OF HIGHER THERMAL
STABILITY" AUTHORED BY FALGUNI PATI AND
OTHERS PUBLISHED IN THE JOURNAL BIORESOURCE
TECHNOLOGY DATED 29.01.2010
Annexure A46 TRUE COPY OF BILL OF ENTRY NO. 5034927 DATED
25.04.2016
Annexure A46(a) TRUE COPY OF INVOICE DATED 01.04.2016
Annexure A46(b) TRUE COPY OF PACKING LIST DATED 01.04.2016
Annexure A46(c) TRUE COPY OF THE COUNTRY-OF-ORIGIN
CERTIFICATE DATED 12.04.2016
Annexure A46(d) TRUE COPY OF TECHNICAL WRITE UP DATED
21.04.2016
Annexure A46(e) TRUE COPY OF THE HEALTH CERTIFICATE DATED
NIL
Annexure A46(f) TRUE COPY OF CERTIFICATE OF ANALYSIS DATED
23.03.2016
Annexure A46(g) TRUE COPY OF BILL OF LADING DATED 08.04.2016
Annexure A46(h) TRUE COPY OF CERTIFICATE FORMING PART OF
MARINE ANNUAL TURNOVER
Annexure A46(i) TRUE COPY OF PURCHASE ORDER DATED 09.03.2016
Annexure A46(j) TRUE COPY OF MARKINGS ON THE PACKAGES OF
IMPORTED GOODS CARRYING THE SAME DESCRIPTION
AS DECLARED BY THE APPELLANT
Annexure A47 TRUE COPY OF SHOW CAUSE NOTICE NO. NO.
SIIB/13/2016-CUS DATED 02.11.2016
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APPENDIX OF CUS. APPEAL 5/2024
PETITIONER'S ANNEXURES
Annexure A TRUE COPY OF ORDER IN ORIGINAL NO.49/17-18
DATED 23-01-2018 ISSUED BY APPELLANT
Annexure B CERTIFIED COPY OF FINAL ORDER NO.20135 DATED
12-03-2024 OF THE CESTAT, REGIONAL BENCH,
BANGALORE ALONG WITH LEGIBLE COPY
RESPONDENTS ANNEXURES: NIL.
//TRUE COPY//
P.S. TO JUDGE
