Section 12(2) in The Customs and Excise and Gold (Control) Appellate Tribunal (Procedure) Rules, 1982
(2)In an appeal or an application by the [Commissioner] [Substituted by the Finance Act, 1995 (22 of 1995), Section 50, for the word 'Collector'.] or the Administrator, the other party shall be made the respondent to the appeal or, as the case may be, application.
