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2016 (9) TMI 774 - CESTAT MUMBAI

2016 (9) TMI 774 - CESTAT MUMBAI - TMI - Recovery of duty foregone in DEPB licence - Cancellation of DEPB licence - DEPB licence obtained fraudulently against submitting fake/forged documents - denial of exemption provided by DEPB licence - goods cleared after verification of the DEPB licence - much after import of the goods the DRI started the investigation and found that all the DEPB licences purchased by the appellants were obtained by various persons fraudulently against submitting the fake/ .....

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ough the licence obtained fraudulently by some other persons. Similar issue has been decided in any cases. The case of Sumit Wool Processors & Others Vs. Commissioner of Customs, Nhavasheva - [2015 (10) TMI 329 - CESTAT MUMBAI] can be referred. - The goods imported and cleared under DEPB licence much before the issue of show-cause notices, therefore at the time of import of the goods and clearance thereof, the DEPB licences were valid in the hands of the appellants-importers - the duty deman .....

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mmon facts in all these appeals are that the appellants have purchased DEPB licence from open market on payment of consideration. Against such DEPB licences they have imported various goods by debiting the duty in the DEPB scrips without payment of duty in cash. The Customs department after verification of the DEPB licences allowed the clearance of the goods. Much after import of the goods the DRI has started the investigation and found that all the DEPB licences purchased by the appellants were .....

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le. Aggrieved by the Order-in-Original the appellants filed these appeals. 2. Learned Counsel for the appellants submits that the appellants have purchased the DEPB licence bonafidely from the market and paid the consideration for such purchase of DEPB licences. At the time of purchase DEPB licence was valid. It is the persons who fraudulently obtained the DEPB licence who have submitted the fake documents to the DGFT and the appellants are not parties to that act of fraud. The appellants had pu .....

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DEPB licence were obtained by some persons fraudulently from DGFT, the appellants-importers cannot be held responsible. He submits that at the time of import and clearance of the goods under the DEPB licence, the DEPB licence were valid therefore import clearance against the valid DEPB licence cannot be questioned. He submit that the issue has been settled in detail in the case of Sumit Wool Processors & Others Vs. Commissioner of Customs, Nhavasheva - [2015-TIOL-2090-CESTAT-MUM]. In other i .....

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ispute that all the appellants have imported the goods by clearing the same against DEPB licence which were purchased by the appellant from the open market against proper payment of the consideration to the seller of the DEPB licence, while purchasing of DEPB licences and even at the time of import the DEPB licence was valid in the hands of the appellants-importers. Therefore, the appellants-importers cannot be made responsible for any fraud committed by some other person for obtaining the DEPB .....

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r to Notification no. 40/2006-Cus dated 1/5/2006 which relates to material imported against DFIA licenses as well as Notification No. 89/2005-Cus dated 4/10/2005 which relates to the DEPB Scheme as reproduced below: Notification No. 40/2006-Cus., dated 1-5-2006 Duty free import authorisation Exemption to materials imported thereagainst In exercise of the powers conferred by sub-section (1) of section 25 of the Customs Act, 1962 (52 of 1962), the Central Government, being satisfied that it is nec .....

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ly, under sections 3, 8 and 9A of the said Customs Tariff Act, subject to the following conditions namely :- (i) that the description, value and quantity of materials imported are covered by the said authorisation and the said authorisation is produced before the proper officer of customs at the time of clearance for debit : Provided that in respect of resultant product specified in paragraph 4.55.3 of the Handbook of Procedures (Vol. I) of the Foreign Trade Policy, the materials permitted in th .....

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rt obligation, the shipping bill number(s) and date(s) and quantity and Free on Board (FOB) value of the resultant product are endorsed on the said authorisation : Provided that where import takes place before fulfilment of export obligation, the quantity and FOB value of the resultant product to be exported are endorsed on the said authorisation; (iii) that the importer at the time of clearance of the imported materials executes a bond with such surety or security and in such form and for such .....

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necessary in respect of imports made after the discharge of export obligation in full; (iv) that the imports and exports are undertaken through seaports at Mumbai, Kolkata, Cochin, Magdalla, Kakinada, Kandla, Mangalore, Marmagoa, Chennai, Nhava Sheva, Paradeep, Pipavav, Sikka, Tuticorin, Visakhapatnam, Dahej, Mundhra, Nagapattinam, Okha, Bedi (including Rozi-Jamnagar), Muldwarka, Porbander, Dharamatar and Vadinar or through any of the airports at Ahmedabad, Bangalore, Bhubaneswar, Mumbai, Kolkat .....

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(Andhra Pradesh), Salem, Malanpur, Singanalur, Jodhpur, Kota, Udaipur, Ahmedabad, Bhiwadi, Madurai, Bhilwara, Pondicherry, Garhi Harsaru, Bhatinda, Dappar (Dera Bassi), Chheharata (Amritsar), Karur, Miraj, Rewari, Bhusawal, Jamshedpur, Surajpur, Dadri, Tuticorin, Kundli, Bhadohi, Raipur, Mandideep, Durgapur and Babarpur or through the Land Customs Station at Ranaghat, Singhabad, Raxaul, Jogbani, Nautanva (Sonauli), Petrapole, Mahadipur, Nepalganj Road, Dawki, Agartala, Sutarkhandi, Amritsar Rai .....

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tity terms) is discharged within the period specified in the said authorisation or within such extended period as may be granted by the Regional Authority by exporting resultant products, manufactured in India which are specified in the said authorisation and in respect of which facility under rule 18 (rebate of duty paid on materials used in the manufacture of resultant product) or sub-rule (2) of Rule 19 of the Central Excise Rules, 2002 or CENVAT credit under CENVAT Credit Rules, 2004 in resp .....

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ays of the expiry of period allowed for fulfilment of export obligation, or within such extended period as the said Deputy Commissioner of Customs or Assistant Commissioner of Customs, as the case may be, may allow; (vii) that exempt materials shall not be disposed of or utilised in any manner, except for utilisation in discharge of export obligation, before the export obligation under the said authorisation has been discharged in full; (viii) that where the Bond filed under condition (iii) agai .....

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and the bond required to be executed by the importer in terms of condition (iii) shall be executed jointly by the merchant-exporter and the supporting manufacturer binding themselves jointly and severally to comply with the conditions specified in this notification; and (b) exempt materials are utilised in the factory of such supporting manufacturer for discharge of export obligation and the same shall not be transferred or sold or used for any other purpose by the said merchant-exporter until t .....

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the importation thereof : Provided that at the time of re-export the materials are identified to the satisfaction of the Deputy Commissioner of Customs or Assistant Commissioner of Customs, as the case may be, as the materials which were imported. Notification No. 89/2005-Cus., dated 4-10-2005 Duty Entitlement Pass Book - Exemption to imports thereunder In exercise of the powers conferred by sub-section (1) of section 25 of the Customs Act, 1962 (52 of 1962), the Central Government, being satisf .....

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toms Tariff Act, as is in excess of the amount calculated at the rate specified in the corresponding entry in column (4) of the said Table; subject to the following conditions, namely :- (i) that the importer has been issued a Duty Entitlement Pass Book by the Licensing Authority in terms of paragraph 4.3 or paragraph 7.9 of the Foreign Trade Policy; (ii) that the importer has been permitted credit entries in the said Duty Entitlement Pass Book by the Licensing Authority at the rates notified by .....

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t Pass Book shall be valid for twenty four months from the date of issue or such extended period as may be granted by the Licensing Authority for import and export only at the port of registration which shall be one of the sea ports at Mumbai, Kolkata, Cochin, Magdalla, Kakinada, Kandla, Mangalore, Marmagoa, Chennai, Nhava Sheva, Paradeep, Pipavav, Sikka, Tuticorin, Visakhapatnam, Dahej, Mundhra, Nagapattinam, Okha, Bedi (including Rozi Jamnagar), Muldwarka and Porbander or through any of the ai .....

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aliwada), Waluj (Aurgangabad), Anaparthy (Andhra Pradesh), Salem, Malanpur, Singanalur, Jodhpur, Kota, Udaipur, Ahmedabad, Bhiwadi, Madurai, Bhilwara, Pondicherry, Garhi Harsaru, Bhatinda, Dappar (Dera Bassi), Chheharata (Amritsar), Karur, Miraj, Rewari, Bhusawal, Jamshedpur, Surajpur, Dadri and Tuticorin or through the Land Customs Station at Ranaghat, Singhabad, Raxaul, Jogbani, Nautanva (Sonauli), Petrapole and Mahadipur or Special Economic Zone as specified in the notification issued under s .....

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on; (v) that where the importer does not claim exemption from the additional duty of customs leviable under section 3 of the Customs Tariff Act, 1975 (51 of 1975), he shall be deemed not to have availed the exemption from the said duty for the purpose of calculation of the said additional duty of customs; (vi) that the importer shall be entitled to avail the drawback or CENVAT credit of additional duty lveiable under section 3 of the said Customs Tariff Act against the amount debited in the said .....

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1. Goods other than edible oils Nil Nil 2. Edible Oils 50% of applied rate of duty 50% of applied rate of additional duty In the first Notification, we find no restriction on the transferee for import of goods on the basis of licenses transferred to him. The only condition applicable to the transferee is in para (2) that benefit will be allowed only if the Certificate bears endorsement of transferability by the Licensing Authority. Similarly in the second notification 89/2005-Cus relating to DEP .....

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procedure for transferability of the License/material imported against such scrips. The transferability is prescribed in para 127 of the Hand Book of Procedures. Sub para (iii) of para 127 states that : 127(i) After export obligation has been fulfilled, export proceeds realised and the BG/LUT redeemed and subject to fulfilment of other conditions as laid down in paragraph 67 of the Policy and Paragraph 126 of the Handbook of Procedures, the value based quantity based licence holder may transfer: .....

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inst which the imports have not been made or have been made partially. From the above, it is clear that transferability is allowed after endorsement to that effect by the licensing authority i.e. DGFT. We were shown documents which are Applications made for transfer of the license. The documents accompanying the application include shipping bills verified by the Customs authorities. We also observe that para 4.49 of the Hand Book of Procedures (2004-2009) provides that the Customs shall verify t .....

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ts on basis of which DEPBs/DFIA Licences were granted as well as at the time of imports under the DEPBs/DFIA Licences. We find that the applications for transfer contained documents such as shipping bills which are signed by the custom officers. Thus the point is that the goods which are later detected by the DRI to have been over valued, were allowed to be exported by the customs officers without pointing any discrepancies in the value and thereafter DGFT allowed transfer of the license on the .....

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hich applies to the transferee is the one which requires that the license should have been made transferable by the licensing authority. The burden of proof that export obligation has been fulfilled is to be discharged by the original licensee. 8.3 The special Ld. Counsel for Revenue stressed that in respect of licenses obtained by fraud, misrepresentation etc., benefit cannot be taken by any one, whether the transferor or transferee otherwise it would lead to a dangerous proposition and enable .....

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): 35. Nor is there any legal basis for the contention that licence obtained by misrepresentation makes the licence non est, with the result that the goods should be deemed to have been imported without licence in contravention of the order issued under Section 3 of the Act so as to bring the case within Clause. (8) of Section 167 of the Sea Customs Act. Assuming that the principles of law of contract apply to the issue of a licence under the Act, a licence obtained by fraud is only voidable : i .....

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Act within the meaning of Clause (8) of Section 167 of the Sea Customs Act. In case of Sampat Raj Dugar(supra), the Honble Apex Court held 21. The next question is whether the import of the said goods was contrary to law in any manner and whether the said goods are liable to be confiscated under the Customs Act. The only provisions relied upon by the appellants are Clauses (d) and (o) in Section 111 of the Customs Act which we have set out hereinabove. In our opinion none of these clauses are .....

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-1963 (3) S.C.R. 338 at 372.] Clause (o) contemplates confiscation of goods which are exempted from duty subject to a condition, which condition is not observed by the importer. Occasion for taking action under this clause arises only when the condition is not observed within the period prescribed, if any, or where the period is not so prescribed, within a reasonable period. It, therefore, cannot be said that the said goods were liable to be confiscated on the date of their import under Clause ( .....

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round that the party had obtained the said licences by fraud and misrepresentation. The Collector held that since the licences had been cancelled ab initio by the Deputy Chief Controller of Imports and Exports there was no licence in existence at the time of import and the goods had been imported in contravention of the provisions of Import and Export (Control) Act and the goods were liable to be confiscated under Section 111(d) of the Act-We are unable to accept this contention of the learned c .....

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ming that the principles of law of contract apply to the issue of a licence under the Act, a licence obtained by fraud is only voidable; it is good till avoided in the manner prescribed by law. 5. In the aforementioned decision of this Court it has been clearly laid down that in a case where the licence is obtained by misrepresentation or fraud it is not rendered non est as a result of its cancellation so as to result in the goods that were imported on the basis of the said licences and being tr .....

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xport Order, 1955 and Import and Export (Control) Act, 1947 and the goods were not liable to be confiscated on that basis under Section 111(d) of the Act. The Special Counsel contended that these judgments of the Apex Court are distinguishable. In the case of East India Commercial Company (supra), he stated, it of about violation of post import condition. And in Sneha Sales Corporation (supra) the issue was of permitting import and not of authorising exemption from duty. He stressed that the Sup .....

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cancelled ab-initio, which according to the Special Counsel means that only importability of the goods was in question and Supreme Court held that even though the licenses were cancelled ab-initio, they are not rendered nonest at the time of import. We note that their Lordships clearly held that license is rendered only voidable. The decision in the case of East India Commercial Company held that license is good till avoided. If we were to agree with the contention that licenses is operative for .....

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there can be no denial of benefit of notification on their plain reading. We also note that in their judgement in the case of TISCO, at the very outset the Hon ble Court stated the question to be whether the extended period under Section 28 is applicable. The facts in the present case are at variance and the question is whether duty liability can be fixed on the transferees of the licensees. 8.4 Special Counsel then drew our attention to the case of Dow Agro Sciences India Pvt. Ltd. 2012 (283) E .....

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njal Showa Ltd. and the case of M/s. Friends Trading Co. Vs. Union of India. In the case of Munjal Showa Ltd. the Honble High Court considered and distinguished the cases of East India Commercial Co. Ltd., Sneha Sales Corporation, Taparia Overseas Pvt. Ltd. and Leader Valves Ltd. The Hon ble High Court took the view that the judgment in the case of Sneha Sales Corporation and East India Commercial Co. Ltd. dealt with the confiscation and not with the payment of duty. We may examine these content .....

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of Gujarat. While affirming this judgment the Honble High Court categorically recorded that the Tribunal had followed the decision of the Supreme Court in the case of Sneha Sales Corporation. In this case of Binani Cement Ltd. we note that the circumstances were similar to the appeals at hand. In those cases also the Licenses were cancelled ab-initio after the transferee had utilized them for import. We also note that the observation of the Hon ble Tribunal decision in the case of Dow Agro Sci .....

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which in any case has taken a dramatically opposite view from the judgment in the case of Leader Valves delivered by the same Court. Further the contention that the earlier Supreme Court judgments such as East India Commercial Co. Ltd., Sneha Sales Corporation would apply only to the issue of importability of goods does not hold good in the face of the Hon ble High Court of Bombay decision in the case of Sanjay Sanwarmal Agarwal Vs. Union of India. It was held therein that : 5. Learned counsel .....

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cal with the contentions which were raised in the case of Taparia Overseas v. Union of India, 2003 (161) E.L.T. 47 (Bom.) = 2002 (2) Bom. C.R. 7; wherein this Court had occasion to deal with the similar contentions and to hold that the concept that fraud vitiates everything would not apply of the cases where the transaction of transfer of licence for a value without notice of alleged fraud arising out of mercantile transaction governed by common law. It was also held that import made under the v .....

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Taparia Overseas v. Union of India (supra) and the petitioner is liable to succeed on merits . Therefore we are not inclined to agree with the Special Counsel. 8.5 Here we would also mention about the discussion of the case of Taparia Overseas Pvt. Ltd. (Mumbai High Court) in the judgment in Dow Agro Sciences India Pvt. Ltd. The Tribunal held that the Taparia Overseas Ltd. was dealing with REP Licenses whose transfer was governed by common law because the licenses were freely transferable. But t .....

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nder a statute. On the point of contention whether fraud vitiates everything we may refer to the Hon'ble High Court of Bombay decision in the case of Taparia Overseas Ltd. (supra). In that case also the import licenses obtained by license holder by fraud were suspended after the import by the transferees. It was held therein that- 28. It is not in dispute that the above procedure was followed by all the petitioners while getting the licences transferred in their respective names. It is, ther .....

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............................................................. ..................................................................... The fact that the contract has been induced by fraud does not make the contract void, or prevent the property passing, but merely gives the party defrauded the right on discovering the fraud to elect whether he shall continue to treat the contract as binding or disaffirm the contract and resume the property. If it can be shown that the party defrauded has at any tim .....

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ermine it either way, subject to this that if in the interval whilst he is deliberating, an innocent third party has acquired an interest in the property, or if in consequence of his delay the position even of the wrongdoer is affected, he will lose his right to rescind. ............................................................... .................................................................. It is thus no doubt true that as a general rule, if a transaction has been originally founded on .....

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e so, the concept that fraud vitiates everything would not be applicable to the cases where the transaction of transfer of licence is for value without notice arising out of mercantile transactions, governed by common law and not by provisions of any statute....................................... On the above canvas, having examined the well settled, established and well recognised concept of law that the effect of fraud is not to render the transaction voidable initio but renders it voidable at .....

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v. Apar Ltd. 1999 (112) E.L.T. 3 (S.C.) and Garden Silk Mills v. Union of India - 1999 (113) E.L.T. 358 (S.C.). The same is the view taken by the Apex Court in Sampat Raj Durgar case (cited supra). Imports against replenishment Licences were permitted duty free if the importers produced an import Replenishment Licence the goods or the materials were imported into India. In the instant cases when the goods were imported into India, and even when the Bills of Entry ware filed, neither were the lic .....

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ussion, we are of the considered opinion that the principles evolved in the case of Goodluck Industries and upheld by Apex Court and followed subsequently in other cases, is to be made applicable to the case on hand, since it is based on sound principle of law. Consequently, we uphold the contentions raised by the appellants while negating the contentions raised by the Department. Therefore the legal maxim LEX NON COGIT AD IMPOSSIBILIA can be invoked and benefit of the same be given to the trans .....

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for value without any notice of fraud, it has to be held that the concept of fraud vitiating everything is not applicable. It was argued that the endorsement of transferability under provisions of EXIM policy being a statutory requirement to make DEPB scrips transferable, the concept of fraud vitiating everything must then be applicable to such transaction. And that this concept was not applicable to transfer of REP Licenses in the case of Taparia Overseas. It was further argued that the DEPB s .....

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efer to the case of Jindal drugs Ltd. Vs. State of Maharashtra [2004(178) ELT 105(Bom). It was held therein that 23. ............ The Apex Court in the case of Jugalkishore v. Raw Cotton Co., A.I.R. 1955 S.C. 376, had occasion to consider the meaning of actionable claim. In this judgment Apex Court ruled that a judgment debt or decree is not an actionable claim because no action is necessary to realise it. It has already been the subject of an action and is secured by the decree. A decree to be .....

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d to materialise in future because its utilisation is dependant upon transferee importing goods covered by the D.E.P.B. scheme. Nor can D.E.P.B. credit be held to be actionable claim because the customs authorities might not recognise the credit therein and the transferee would have to commence action against them in the Court of law. In our opinion, the transfer of D.E.P.B. credit confers upon the transferee a right which is choate and perfected and exercisable immediately. 24. The Apex Court i .....

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for performance. The property aspect is relevant for purpose of assignment, administration, taxation and the like, the contractual aspect for performance. Therefore, in our view, the credit entry in the D.E.P.B. cannot be described as an actionable claim ................................................... 27. ................... In the submission of the learned Counsel for the petitioners, reliance on the judgment of the Vikas Sales Corporation (supra) by the Delhi High Court was erroneous. In h .....

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Corporation (supra) while deciding that the credit in the D.E.P.B. is goods is not correct in law. He further submitted that the Delhi High Court while deciding the case in Philco Exports (supra) and the Apex Court in the case of Vikas Sales Corporation (supra), in turn, relied upon its earlier judgment in the case of [N. Anraj v. Government of Tamil Nadu], A.I.R. 1986 S.C. 63, holding that R.E.P. licence is not an actionable claim. 29. The Delhi High Court rightly relied upon the case of Vikas .....

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tion 29 of this Act deals with Sale by a person in possession under a voidable contract. It states When the seller of the goods has obtained possession thereof under a contract voidable under Section 19 or Section 19A of the Indian Contract Act, 1872, but the contract has not rescinded at the time of the sale, the buyer acquires a god title to the goods, provided he buys them in good faith and without notice of the sellers defect of title . In the present situation the contracts were voidable in .....

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n if the representations made had been true. Exception: if such consent was caused by misrepresentation or by silence, fraudulent within the meaning of section 17, the contract, nevertheless is not voidable, if the party whose consent was as caused had the means of discovering the truth with ordinary diligence. 19-A. Power to set aside contract induced by undue influence- When consent to an agreement is caused by undue influence, the agreement is a contract voidable at the option of the party wh .....

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we are convinced that effect of misrepresentation in the present cases has not rendered the transaction between the original license holders and the transferees void ab-inito but rendered it voidable at the instance of the party( in this case importer)defrauded and transaction continues to be valid until the party defrauded has decided to avoid it. In the present case the licences/scrips were transferred to the appellant importers who had no knowledge of the misrepresentation by the exporters in .....

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provides that in such cases duty shall be recovered from the person to whom the instruments (such as DEPB) is issued. If law had been so clear that duty could be demanded from the transferee, there would have been no need to introduce Section 28 AAA in the statute. 8.6 Ld. Spl. Counsel for Revenue also relies on the Apex Court Judgment in case of M/s. FEDCO (P) Ltd. to make the point that when a license is obtained by fraud or mis-representation, it would be reasonable to think that the person .....

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culars on the basis of which the licenses were proposed to be cancelled and sought permission to inspect the papers. However no particulars were furnished and no inspection was allowed. The licenses were cancelled. Therefore two issues arose before the Hon ble Apex Court; the first issue was whether cancellation is a reasonable restriction on exercise of fundamental rights. Hon ble Court held that We are therefore of opinion that the provision that license may be cancelled, if it is found, after .....

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one without allowing inspection of records. The court held that the order of cancellation was made in utter disregard of principles of natural justice, without expressing opinion on merits. This judgment has no bearing on the facts of the present case before us. In that case there was no situation of transfer of licenses. The Apex Court never considered whether duty liability can be fixed on the transferee of licenses which were obtained by mis-representation by the transferor. Reliance on this .....

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at his result has been withheld because of the allegation of having used unfair means. He suppressed this fact and took admission in B.A. and studied thereafter. In this context the Hon ble Court held that benefit of fraud cannot be allowed to be enjoyed. However in the present case before us no evidence of fraud is produced as far as transferees of the licences are concerned. Similarly, other judgment of K.I. International Ltd. (supra) is on a different platform. In this case the element benefi .....

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urnam Kaur 1989 AIR 38, 1988 SCR Supl. (2) 929 dt. 12.9.1988 it was held that that: Pronouncements of law, which are not part of the ratio decidendi are classed as obiter dicta and are not authoritative. With all respect to the learned Judge who passed the order in Jamna Das' case and to the learned Judge who agreed with him, we cannot concede that this Court is bound to follow it. It was delivered without argument, without reference to the relevant provisions of the Act conferring express p .....

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ute. So far as the order shows, no argument was addressed to the Court on the question or not whether any direction could properly be made compelling the Municipal Corporation to construct a stall at the pitching site of a PG NO 939 pavement squatter. Professor P.J. Fitzgerald, editor of the Salmond on Jurisprudence, 12th edn. explains the concept of sub silentio at p. 153 in these words: "A decision passes sub silentio, in the technical sense that has come to be attached to that phrase, wh .....

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n the facts and although the case had a specific outcome, the decision is not an authority on point B. Point B is said to pass sub silentio . In view of this judgment, we hold that the judgment cited by Spl. Counsel is per incuriam. The judgments in the case of East India Commercial Company and Sneha Sales Corporation would hold fort in the circumstances. 8.8 In view of analysis above based on judicial pronouncements, we set aside the confiscation, demands of duty and interest and penalties. 8.9 .....

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7(J), every order of the Settlement Commission passed under Section 127(C) shall be conclusive and no matter covered by such order shall be re-opened in any proceedings under this Act. Therefore duty demand against these importers are set aside on this ground also, apart from confiscation and penalties. In some cases, the exporter had deposited duty at the investigation stage on behalf of the importer also. In such cases too, the question of demanding duty to the extent of amount already deposit .....

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wed in above terms. 6. In all the present cases, the fact that the licence obtained fraudulently came into notice of the DRI only after the goods imported and cleared under the said DEPB licence. A chart showing date of Bills of Entry and date of show-cause notice is given below:- Sl. No. Appeal No. Appellant/Importer Bills of Entry No. & Date Show-cause notice No. & Date 1. C/1122/04 M/s Alpha Chemie Sapthagiri 98/01.09.98 S/16-Misc.-1243/98 Gr. 7 dated 29.01.1999 130/03.10.1998 S/26-Mi .....

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