Can Section 114AA be invoked merely because a Bill of Entry contains an incorrect declaration? Can a Customs Broker be penalised for a false declaration made by the importer?
The answer is not as simple as “misdeclaration = Section 114AA”.
Recent judicial developments have made the law considerably more interesting. On one side, the Revenue increasingly invokes Section 114AA in import cases involving alleged misdeclaration, undervaluation, classification disputes and incorrect documents. On the other, High Courts have repeatedly insisted that a penal provision containing the words “knowingly or intentionally” cannot be converted into a routine penalty for every error committed in a Customs transaction.
The controversy becomes even sharper when the noticee is a Customs Broker.
Is a Customs Broker merely liable to exercise professional diligence under the Customs Broker Licensing Regulations? Or can the Broker also be branded as a person who has knowingly or intentionally used a false document merely because the document supplied by the importer was filed through the Broker?
The answer lies in understanding the statutory architecture of Section 114AA—and, more importantly, in distinguishing an incorrect declaration from a knowingly false declaration.
1. The statutory provision: What exactly does Section 114AA punish?
Section 114AA provides for penalty where a person:
“Knowingly or intentionally makes, signs or uses, or causes to be made, signed or used”
a declaration, statement or document which is:
“False or incorrect in any material particular”
in a transaction of business for the purposes of the Customs Act.
This wording is critical.
Section 114AA does not merely say:
“If a declaration is incorrect, penalty shall follow.”
Parliament inserted several qualifying expressions.
The provision therefore contains a chain of statutory requirements:
THE SECTION 114AA TEST
PERSON
↓
MAKES / SIGNS / USES / CAUSES TO BE MADE, SIGNED OR USED
↓
DECLARATION / STATEMENT / DOCUMENT
↓
FALSE OR INCORRECT
↓
IN A MATERIAL PARTICULAR
↓
KNOWINGLY OR INTENTIONALLY
If one of these essential ingredients is missing, the foundation of the Section 114AA penalty becomes questionable.
2. The first big question: Was Section 114AA intended for exports or imports?
This controversy has existed for years.
The provision was introduced in 2006 against the background of serious fraudulent export practices.
The legislative material indicates concern about transactions in which:
- exports were falsely shown;
- documents were fabricated;
- goods were not actually exported;
export incentives were claimed on the basis of false documentation.
This legislative history led several Tribunal decisions to take the view that Section 114AA was essentially directed towards fraudulent export transactions.
That line of reasoning appeared in cases such as:
- A.V. Global Corporation Pvt. Ltd.
- Access World Wide Cargo
- Sri Krishna Sounds & Lightings
- Interglobe Aviation Ltd.
- Suresh Kumar Aggarwal
The argument was simple:
If the mischief Parliament intended to address was fraudulent export documentation, Section 114AA should not automatically be expanded into a general penalty provision for every import discrepancy.
But there is a serious difficulty with relying exclusively upon that argument today.
3. The words Parliament actually enacted matter
The enacted Section 114AA does not expressly say:
“in relation to export.”
Instead, Parliament used the wider expression:
“in the transaction of any business for the purposes of this Act.”
This wording has become central to the Revenue's case in recent years.
The argument is:
Bill of Entry
↓
Import transaction
↓
Transaction of business under the Customs Act
↓
False material declaration
↓
Knowledge/intention
↓
Section 114AA
This interpretation received significant support from the Delhi Bench of CESTAT in Nitin Khandelwal v. Principal Commissioner of Customs, Final Order No. 51338/2025, decided on 23 September 2025.
4. Nitin Khandelwal: A major development for importers
Nitin Khandelwal v. Principal Commissioner of Customs
CESTAT, Delhi — Final Order No. 51338/2025
The case involved allegations of undervaluation of imported goods and parallel invoices.
One of the principal arguments was that Section 114AA was intended for export transactions and could not be applied to an import transaction.
The Tribunal rejected that broad proposition.
It reasoned that:
- a Bill of Entry is a document used in Customs business;
- import is a transaction under the Customs Act;
- Section 114AA contains no express limitation restricting it to exports;
the legislative history explaining the background of the provision cannot override the wording finally enacted by Parliament.
The message from Nitin Khandelwal is therefore significant:
Section 114AA can potentially apply to an import transaction.
But there is an equally important second part of the decision.
The Tribunal did not treat every person associated with the importer as automatically liable.
Where the case against individual partners was not supported by independent evidence establishing their specific involvement, the Section 114AA penalty could not simply be sustained merely because the importing firm had committed the alleged violation.
Therefore:
Import transaction may be covered.
But:
individual liability still requires individual statutory ingredients.
That distinction becomes crucial in the case of Customs Brokers.
5. Orion Enterprises: The High Court enters the debate
Commissioner of Customs, Chennai-II v. M/s Orion Enterprises
Madras High Court — 22 April 2026
The 2026 decision of the Madras High Court is an important development.
The case concerned an importer against whom the Department alleged serious misdeclaration involving matters such as:
- seating capacity;
- country of origin;
- declared value;
- documentation;
eligibility for a duty concession.
Section 114AA penalty was imposed.
The Tribunal had set aside the penalty, but the matter reached the High Court.
The High Court ultimately allowed the Department's appeal.
One important issue was whether an importer could escape Section 114AA merely because the importer had not physically fabricated the false document.
The answer was effectively no.
Why?
Because Section 114AA does not punish only the person who physically manufactures a false document.
It also covers a person who:
uses
or
causes to be made, signed or used
the false material.
This is a critical statutory distinction.
6. But Orion Enterprises does NOT mean every import error attracts Section 114AA
This point needs emphasis.
The decision should not be misunderstood as establishing the following formula:
Wrong declaration = Section 114AA.
That would ignore the words:
“Knowingly or intentionally”
and
“False or incorrect in any material particular.”
The real proposition is narrower:
Where an import transaction involves a false or incorrect material declaration and the evidence establishes that the person knowingly or intentionally made, signed, used or caused the false material to be used, Section 114AA can be attracted.
That is very different from penalising an importer merely because Customs subsequently disagrees with his classification, valuation or description.
7. This brings us to the real issue: What is “false”?
A declaration can be:
Incorrect
without necessarily being:
Knowingly false.
This distinction is fundamental in Customs litigation.
Consider a classification dispute.
The importer declares:
CTH 2106
Customs subsequently says:
CTH 2309
The fact that Customs ultimately succeeds in classification proceedings does not automatically establish that the importer:
knowingly or intentionally
made a false declaration.
A classification dispute may involve:
- competing tariff headings;
- GIR interpretation;
- HSN Explanatory Notes;
- chapter notes;
- competing judicial decisions;
- technical literature;
interpretational uncertainty.
Such a dispute is conceptually different from:
“I know the goods are classifiable under Heading A, but I deliberately declared Heading B to obtain an unlawful duty benefit.”
The latter is much closer to the mischief addressed by Section 114AA.
8. Section 111(m) does not automatically become Section 114AA
This is perhaps one of the most important safeguards against mechanical penalty proceedings.
Section 111 deals with circumstances in which imported goods become liable to confiscation.
Section 112 deals with penalties for improper importation and related conduct.
Section 114AA addresses a different statutory wrong:
knowing or intentional use or making of false or incorrect material documentation/declarations.
Therefore:
Section 111(m) finding
does not automatically mean:
Section 114AA penalty.
Similarly:
Section 112 penalty
does not automatically establish:
Section 114AA liability.
The Department must establish the independent ingredients of Section 114AA.
9. The six questions every Section 114AA case should answer
Before imposing a Section 114AA penalty, the adjudicating authority should logically answer six questions.
QUESTION 1
What is the precise declaration, statement or document?
Is it:
Bill of Entry?
Invoice?
Packing List?
Certificate of Origin?
Valuation declaration?
Technical document?
Import licence?
Other document?
QUESTION 2
What exactly is false or incorrect?
The order must identify the actual falsehood.
A generic statement such as:
“The noticee made a false declaration”
is not enough.
QUESTION 3
Why is the particular falsehood material?
Section 114AA specifically refers to a false or incorrect declaration:
“in any material particular.”
Materiality therefore cannot simply be assumed.
QUESTION 4
Who actually made, signed or used the document?
This becomes particularly important where several persons are involved:
- importer;
- director;
- partner;
- authorised employee;
- Customs Broker;
- overseas supplier;
freight forwarder.
QUESTION 5
What evidence proves knowledge?
Was there:
an admission?
email correspondence?
instructions?
parallel documents?
manipulation?
previous declarations?
internal records?
financial evidence?
technical knowledge?
deliberate concealment?
QUESTION 6
What establishes intention?
An incorrect result is not itself proof of an intentional falsehood.
The Department must bridge the evidentiary gap between:
“wrong”
and
“knowingly/intentionally false.”
10. The Customs Broker problem
Now consider a typical import transaction.
The importer provides:
- commercial invoice;
- packing list;
- Bill of Lading;
- Certificate of Origin;
- product description;
- valuation information;
classification instruction.
The Customs Broker prepares and files the Bill of Entry.
Later Customs discovers that the importer:
- undervalued the goods;
- misclassified the goods;
- submitted a false certificate;
misstated technical specifications.
Can Section 114AA automatically be imposed upon the Customs Broker?
No.
The answer requires a separate examination of the Broker's own conduct.
The critical question is not:
“Did the Broker file the document?”
The critical question is:
“Did the Broker knowingly or intentionally make, sign, use or cause to be made, signed or used the false or incorrect material?”
That is a substantially higher threshold.
11. HLPL Global Logistics: A powerful Customs Broker precedent
HLPL Global Logistics Pvt. Ltd. v. Commissioner of Customs (ACC)
Delhi High Court — 22 November 2023
This is one of the most important authorities for a Customs Broker facing Section 114AA proceedings.
The case involved allegations against the Customs Broker concerning the importer's documentation/KYC-related conduct.
The Delhi High Court examined Section 114AA and rejected the proposition that the Broker could be penalised merely because documents filed through the Broker were subsequently found to contain irregularities.
The Court stressed the necessity of establishing the statutory conduct attributable to the Broker.
The practical proposition is:
A Customs Broker is not automatically the guarantor of the truthfulness of every statement or document supplied by an importer.
If the Department wants to impose Section 114AA penalty, it must establish the Broker's own knowing and intentional involvement.
This principle is reinforced by the Delhi High Court's jurisprudence concerning the limited role of Customs Brokers.
12. Kunal Travels: A Customs Broker is not an investigator
Kunal Travels (Cargo) v. Commissioner of Customs (I&G)
Delhi High Court
The decision in Kunal Travels remains important in understanding the legal position of a Customs Broker.
A Customs Broker performs a professional facilitation function.
The Broker is not expected to transform himself into:
an investigator of every commercial transaction of his client.
The distinction is fundamental.
A Customs Broker may have a duty to:
- obtain prescribed documents;
- comply with KYC requirements;
- exercise prescribed diligence;
follow the Customs Broker Licensing Regulations.
But that does not necessarily mean:
every false statement made by the importer becomes the Broker's knowingly false statement.
This distinction is particularly important when the Department attempts to convert a CBLR lapse into Section 114AA liability.
13. Trinetra Impex: Conscious involvement matters
Commissioner of Customs (Import) v. Trinetra Impex Pvt. Ltd.
Delhi High Court — 11 October 2019
The case involved a Customs Broker and allegations surrounding forged documentation.
The High Court examined the Broker's role and found that the evidence did not establish the kind of conscious involvement necessary to sustain the penal consequences.
The principle emerging from the decision is highly relevant:
A Customs Broker cannot be penalised merely because fraudulent documents passed through his hands. There must be evidence connecting him consciously with the fraud.
The difference between:
handling a document
and
knowingly using a false document
is the difference between ordinary professional activity and Section 114AA conduct.
14. Nandkumar Pawar: Bombay High Court gives a vital warning
Nandkumar Pawar v. Union of India
Bombay High Court — 4 February 2026
This is particularly significant from the perspective of Customs Brokers.
The case involved substantial penalties, including a very large penalty under Section 114AA.
The Department alleged involvement of the Customs Broker in misuse of an importer's IEC and related transactions.
The Bombay High Court emphasized the necessity of establishing the precise role of the noticee.
The Court's reasoning provides an important practical lesson:
The adjudicating authority cannot merely reproduce the language of Section 114AA and declare that the noticee “knowingly and intentionally” made a false declaration.
The authority must explain:
- what the false declaration was;
- which document was involved;
- what the Broker actually did;
- how the Broker participated;
- what evidence establishes knowledge;
what evidence establishes intention.
A finding of liability must be specific and reasoned.
This is a powerful safeguard against mechanical invocation of Section 114AA.
15. P.S. Bedi & Co.: Wrong classification is not automatically fraud by the Broker
P.S. Bedi & Co. Pvt. Ltd. v. Commissioner of Customs
CESTAT, Delhi — 5 August 2025
The case involved classification of imported water meters.
The Department sought to impose penalties upon the Customs Broker, including under Section 114AA.
The Tribunal found insufficient evidence demonstrating that the Broker had itself knowingly or intentionally made or used a false declaration.
The penalty was therefore set aside.
Why is this important?
Because classification is frequently the battleground in Customs disputes.
A Broker may enter the classification indicated by the importer or based upon the documents/information available to him.
If Customs subsequently takes a different legal view, that does not automatically establish:
fraudulent use of a false document.
A classification dispute cannot casually be transformed into a Section 114AA offence.
16. The crucial distinction: CBLR negligence versus Section 114AA
This distinction should be at the heart of every Customs Broker defence.
Suppose a Broker failed to conduct adequate verification.
That may constitute:
a breach of the Customs Broker Licensing Regulations.
But the statutory consequence of that breach does not automatically become:
Section 114AA penalty.
Why?
Because the two provisions address different conduct.
CBLR
Focuses upon professional obligations and regulatory compliance.
Section 114AA
Focuses upon:
knowing or intentional falsification/use of material documentation.
Therefore:
Regulatory negligence ≠ deliberate falsification.
17. When CAN Section 114AA legitimately apply to a Customs Broker?
The answer is not that a Customs Broker is immune.
A Broker can potentially fall within Section 114AA.
Consider this example.
The importer provides an invoice showing:
USD 100,000
The Broker has independent knowledge that the actual transaction value is:
USD 300,000
The Broker nevertheless deliberately files the lower-value document.
Now the Department has a much stronger case.
Why?
Because the evidence may establish:
Knowledge
Intention
Use of false material
Materiality
Customs transaction
That is qualitatively different from simply filing an importer-supplied document without knowledge of its falsity.
18. Another example: forged Certificate of Origin
Scenario A — Innocent filing
The importer provides a forged Certificate of Origin.
The Broker has no reason to suspect it is forged.
The Broker files it.
Result:
A Section 114AA case against the Broker is considerably weaker.
Scenario B — Knowing use
The Broker discovers that the Certificate of Origin is forged.
He nevertheless deliberately uses it to obtain preferential duty treatment.
Result:
The case for Section 114AA becomes substantially stronger.
The key difference is not:
Who physically created the document?
The key question is:
Who knowingly and intentionally used it?
19. The words “causes to be made, signed or used” are important
A Customs Broker cannot always escape Section 114AA simply by saying:
“I did not create the false document.”
That is not sufficient if evidence shows that the Broker:
- instructed its preparation;
- manipulated information;
- directed another person to use it;
- knowingly arranged its submission;
participated in the creation or use of the false document.
Parliament deliberately included the expression:
“causes to be made, signed or used.”
Therefore, physical authorship is not the only route to liability.
But again, the Department must prove the required knowledge and intention.
20. The evidentiary question: Where is the evidence?
A Section 114AA order should not rest upon suspicion.
The Department should be able to point to evidence such as:
Documentary evidence
- emails;
- WhatsApp/other communications;
- instructions;
- internal correspondence;
- altered documents;
- parallel invoices;
contradictory declarations.
Conduct evidence
- repeated deliberate misdeclarations;
- unusual routing;
- deliberate concealment;
active manipulation.
Financial evidence
- sharing of unlawful benefits;
- payment arrangements;
unexplained commissions.
Admission evidence
- statements;
- admissions;
acknowledgments of knowledge.
Without such evidence, the order risks becoming a conclusion rather than a finding.
21. “Knowledge” cannot simply be presumed from professional status
This is especially important for Customs Brokers.
The Department may argue:
“The Broker is a professional. Therefore he should have known.”
But there is a fundamental difference between:
“He should have known”
and
“He actually knew and intentionally acted.”
The first may support an argument of:
negligence / lack of due diligence.
The second is what Section 114AA requires.
Therefore:
Professional competence cannot automatically be converted into statutory knowledge of fraud.
22. Parliamentary history: Useful—but not conclusive
The legislative history remains relevant.
The Standing Committee's consideration of the provision demonstrates that the legislation arose against the background of fraudulent export practices.
The Supreme Court in Kalpana Mehta v. Union of India recognized that Parliamentary Committee material may, in appropriate circumstances, be considered to understand the historical context and legislative background.
But there is an important qualification.
A Parliamentary Committee Report cannot ordinarily override clear statutory language enacted by Parliament.
Therefore, the better argument today is not:
“The Standing Committee discussed exports, therefore Section 114AA can never apply to imports.”
That proposition has become difficult to sustain after Nitin Khandelwal and Orion Enterprises.
The better argument is:
“The legislative history demonstrates the mischief sought to be addressed and reinforces the need to apply the provision to genuine cases of deliberate falsification, rather than converting it into a general penalty for every import discrepancy.”
That is a much more defensible proposition.
23. The present legal position: Importer versus Customs Broker
| Issue | Importer | Customs Broker |
|---|---|---|
| Can Section 114AA apply? | Yes | Potentially yes |
| Can it apply to an import transaction? | Yes, according to recent jurisprudence | Potentially |
| Mere incorrect declaration sufficient? | No | No |
| Knowledge required? | Yes | Yes |
| Intention required? | Yes | Yes |
| Mere classification dispute? | Normally insufficient | Normally insufficient |
| Mere valuation dispute? | Not automatically sufficient | Not automatically sufficient |
| Merely filing importer documents? | N/A | Not automatically 114AA |
| CBLR/KYC lapse? | N/A | Not by itself 114AA |
| Knowing use of forged document? | Yes | Yes |
| Fabrication of false document? | Yes | Yes |
| Causing false document to be used? | Yes | Yes |
| Mere association with importer? | No | No |
| Section 111(m) automatically proves 114AA? | No | No |
| Section 112 automatically proves 114AA? | No | No |
24. The five-question defence test
Whenever Section 114AA is invoked, ask:
QUESTION 1
What exactly is the false document?
If the Department cannot identify it precisely, the charge is immediately vulnerable.
QUESTION 2
What exactly is false?
“Misdeclaration” is a conclusion.
The authority must identify the actual falsehood.
QUESTION 3
Why is it material?
The statute requires falsity in a material particular.
QUESTION 4
What exactly did this noticee do?
Not:
“The importer did it.”
Not:
“The Broker filed the Bill of Entry.”
But:
What statutory act did this particular noticee perform?
QUESTION 5
What proves knowledge and intention?
This is the ultimate question.
If the answer is merely:
“Because the declaration was wrong,”
the reasoning may be circular.
The Department must establish:
wrong + knowledge + intention + materiality + statutory act.
25. The real dividing line
The entire Section 114AA jurisprudence can be reduced to one distinction:
ERROR
versus
DELIBERATE FALSEHOOD
A Customs dispute involving:
- interpretation;
- classification;
- valuation;
- technical description;
- exemption eligibility;
does not automatically become a Section 114AA case merely because Customs ultimately takes a contrary position.
But where evidence demonstrates:
“I knew the declaration was false, and I deliberately used it to achieve a Customs consequence,”
the case changes completely.
26. A practical illustration
Consider two importers.
Importer A
Imports a technical product.
Based upon the HSN literature and previous assessments, he believes Heading X is correct.
Customs subsequently determines Heading Y is correct.
Importer B
Knows Heading Y applies.
Internal emails show that he instructs his employees:
“Declare Heading X because the duty is lower.”
Importer A
Classification dispute.
Importer B
Potentially:
Section 114AA case.
The difference is not the ultimate classification.
The difference is:
knowledge + intention.
27. The same logic applies to Customs Brokers
Broker A
Receives an invoice and classification information from the importer.
He has no reason to suspect fraud.
He files the Bill of Entry.
Customs later discovers an incorrect declaration.
Broker B
Knows the importer has deliberately undervalued the goods.
The Broker participates in preparing the false documents and deliberately files them.
Broker A
Potentially a regulatory/due-diligence issue.
Broker B
Potentially Section 114AA.
This is precisely why the role of the individual noticee must be separately examined.
28. The strongest argument for a Customs Broker
A Customs Broker facing Section 114AA proceedings should not ordinarily rely upon only one argument:
“Section 114AA applies only to exports.”
That argument has become vulnerable after the recent jurisprudence.
The stronger strategy is:
FIRST:
Assume, without admitting, that Section 114AA can apply to an import transaction.
THEN:
Ask whether the Department has proved every statutory ingredient.
The defence should therefore be:
Even assuming Section 114AA applies to imports, the impugned order fails because it does not establish that the Customs Broker knowingly or intentionally made, signed, used or caused to be made, signed or used any false or incorrect declaration, statement or document in any material particular.
This approach directly attacks the statutory foundation of the penalty.
29. The ideal appellate ground
A Customs Broker could formulate the central ground broadly as follows:
“The impugned order mechanically invokes Section 114AA by equating the existence of an incorrect declaration in the Bill of Entry with the statutory act of knowingly or intentionally making, signing, using or causing to be made, signed or used a false or incorrect declaration in a material particular. The order fails to identify the specific false declaration attributable to the Appellant, fails to establish the Appellant's knowledge of its falsity, fails to establish intentional conduct, and fails to distinguish a professional filing/due-diligence obligation under the Customs Broker Licensing Regulations from the distinct and more onerous statutory ingredients of Section 114AA.”
That is, in my view, a substantially stronger ground than simply saying:
“114AA applies only to exports.”
30. The emerging judicial position
The authorities now suggest the following framework.
For IMPORTERS
The export-only argument is losing force.
Nitin Khandelwal (2025) and Orion Enterprises (2026) make it increasingly difficult to contend that Section 114AA can never apply to imports.
But the Revenue still has to establish:
false/incorrect material declaration + knowledge + intention + statutory act.
For CUSTOMS BROKERS
There is no absolute statutory immunity.
But neither is there automatic liability.
The Department must establish the Broker's own conscious participation.
HLPL Global Logistics, Trinetra Impex, Kunal Travels, P.S. Bedi & Co., and Nandkumar Pawar provide substantial support for resisting mechanical invocation of Section 114AA against intermediaries.
31. The ultimate legal principle
Section 114AA should therefore not be understood as:
“Penalty for wrong Customs declaration.”
Its proper character is closer to:
“Penalty for knowingly or intentionally making, signing, using, or causing to be made, signed or used a materially false or incorrect declaration, statement or document in Customs business.”
That distinction is not semantic.
It determines liability.
32. Final takeaway
For an importer
Section 114AA can apply to imports.
But an incorrect declaration does not automatically establish Section 114AA.
The Department must prove:
FALSE MATERIAL
KNOWING
INTENTIONAL
STATUTORY ACT
For a Customs Broker
Section 114AA cannot be treated as an automatic consequence of filing the importer's documents.
A Customs Broker may become liable where evidence establishes that he:
- knew the document was false;
- intentionally used it;
- made or signed it knowing it was false;
- fabricated or manipulated it;
or knowingly caused it to be made, signed or used.
But:
mere filing, mere association with the importer, a subsequent finding of misdeclaration, or a CBLR/KYC lapse does not by itself establish Section 114AA liability.
THE SECTION 114AA LITIGATION FORMULA
WRONG DECLARATION
KNOWINGLY FALSE DECLARATION
and
CUSTOMS BROKER FILED THE DOCUMENT
CUSTOMS BROKER KNOWINGLY USED A FALSE DOCUMENT
The real question in every Section 114AA proceeding should therefore be:
“WHERE IS THE EVIDENCE OF KNOWLEDGE AND INTENTION?”
That is where the statutory text, the evidence and the judicial precedents ultimately converge.
Key authorities
Indusind Media & Communications Ltd. v. Commissioner of Customs, Supreme Court, 2019.
Kalpana Mehta v. Union of India, Supreme Court, 2018 — relevance of Parliamentary Committee material.
Kunal Travels (Cargo) v. Commissioner of Customs (I&G), Delhi High Court.
Commissioner of Customs (Import) v. Trinetra Impex Pvt. Ltd., Delhi High Court, 2019.
HLPL Global Logistics Pvt. Ltd. v. Commissioner of Customs (ACC), Delhi High Court, 2023.
Hera Shipping Solutions Pvt. Ltd. v. Commissioner of Customs, CESTAT Chennai, 2022.
Suresh Kumar Aggarwal v. Additional Director, CESTAT Mumbai, 2024.
P.S. Bedi & Co. Pvt. Ltd. v. Commissioner of Customs, CESTAT Delhi, 2025.
Nitin Khandelwal v. Principal Commissioner of Customs, CESTAT Delhi, Final Order No. 51338/2025, 23.09.2025.
Nandkumar Pawar v. Union of India, Bombay High Court, 04.02.2026.
Commissioner of Customs, Chennai-II v. M/s Orion Enterprises, Madras High Court, 22.04.2026.