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Custom, Excise & Service Tax Tribunal

A Mariappan vs Commissioner Of Customs Air ... on 8 May, 2026

     CUSTOMS, EXCISE AND SERVICE TAX APPELLATE TRIBUNAL
                          CHENNAI

                            REGIONAL BENCH - COURT No. III


                    1. Customs Appeal No. 40309 of 2024
(Arising out of Order-in-Original No. 32/2024-AIR dated 03.02.2024 passed by Principal Commissioner of
Customs (Air Cargo), New Custom House, Meenambakkam, Chennai - 600 016)


Mr. A. Mariappan                                                                     ...Appellant
No. 51/54, Gokulam Flats,
State Bank Colony Main Road,
Nanganallur,
Chennai - 600 061.

                                             Versus

Commissioner of Customs                                                            ...Respondent
Chennai VII Commissionerate,
New Custom House,
Meenambakkam,
Chennai - 600 016.

                                                With

  2. Customs Appeal No. 40310 of 2024 (M/s. BSM Logistics)
  3. Customs Appeal No. 40323 of 2024 (Commr. of Customs, Chennai VII)
  4. Customs Appeal No. 40329 of 2024 (Commr. of Customs, Chennai VII)
  5. Customs Appeal No. 40330 of 2024 (Commr. of Customs, Chennai VII)
  6. Customs Appeal No. 40331 of 2024 (Commr. of Customs, Chennai VII)
  7. Customs Appeal No. 40332 of 2024 (Commr. of Customs, Chennai VII)
  8. Customs Appeal No. 40333 of 2024 (Commr. of Customs, Chennai VII)
  9. Customs Appeal No. 40334 of 2024 (Commr. of Customs, Chennai VII)
  10. Customs Appeal No. 40336 of 2024 (Mr. T. Sankara Kumar)
  11. Customs Appeal No. 40365 of 2024 (Mr. Nerella Samueal Deepak Avinash)
  12. Customs Appeal No. 40541 of 2024 (Mr. Ashok Jain)
  13. Customs Appeal No. 40542 of 2024 (Mr. Narendra Sharma)
  14. Customs Appeal No. 40543 of 2024 (Mr. Sunil Sharma)

APPEARANCE:

For the Assessee :    Mr. A.K. Jayaraj, Advocate (Sl.Nos. 1,2,13)
                      Mr. C. Mohan, Mr. M. Kumaresan, Ms. Dhilshath, Advocates (Sl.No. 3)
                      Mr. A. Ganesh, Advocate (Sl.Nos. 8,11)
                      Mr. Aliakbar Devjani, Advocate (Sl.Nos. 5,12,14)
                      Mr. T. Sankara Kumar, Party in-person (Sl.No. 10)

For the Respondent : Mr. Anoop Singh, Authorised Representative

CORAM:
HON'BLE MR. P. DINESHA, MEMBER (JUDICIAL)
HON'BLE MR. VASA SESHAGIRI RAO, MEMBER (TECHNICAL)
                                       2



             FINAL ORDER Nos. 40587-40600 / 2026

                                           DATE OF HEARING : 27.11.2025
                                           DATE OF DECISION : 08.05.2026

     Per Mr. VASA SESHAGIRI RAO


           The present appeals and cross-appeals arise out of

     Order-in-Original No. 32/2024-AIR dated 03.02.2024 passed

     by the Principal Commissioner of Customs (Air Cargo),

     Chennai-VII Commissionerate. Since all the appeals emanate

     from the same Order-in-Original, involve common facts,

     common evidence and overlapping issues of law, they are

     taken up together and disposed of by this common order in

     respect of the undermentioned Appeals as tabulated below: -

                              Appellant
Sl.               Appeal      Name /           Capacity /     Duty / Penalty
    Appeal No.
No.               Filed By    Authority        Description    Involved
                              S/Shri
                                                             Penalty under
                                               CEO, M/s
1    C/40309/2024 Assessee    A. Mariappan                   Customs Act (as per
                                               BSM Logistics
                                                             OIO)
                              M/s BSM          Customs       Penalty under Section
2    C/40310/2024 Assessee
                              Logistics        Broker Firm   114(iii)
                              T. Sankara       Partner, M/s  Penalty under Section
3    C/40336/2024 Assessee
                              Kumar            BSM Logistics 114(iii)
                              Nerella
                              Samuel           Appraiser of   Penalty under Sections
4    C/40365/2024 Assessee
                              Deepak           Customs        112(ii) / 114(iii)
                              Avinash
                                               Associated
5    C/40541/2024 Assessee    Ashok Jain                      Personal penalty
                                               Person
                              Narendra         Associated
6    C/40542/2024 Assessee                                    Personal penalty
                              Sharma           Person
                                               Proprietor,
                                               M/s Shree      Penalty / confiscation
7    C/40543/2024 Assessee    Sunil Sharma
                                               Balaji         related
                                               Jewellers
                                                        Release / liability
                             Commissioner
8    C/40323/2024 Department              HDFC Bank     relating to seized
                             of Customs
                                                        goods
                             Commissioner Shri Zillur   Confiscation /
9    C/40332/2024 Department
                             of Customs   Mondal        redemption fine
10   C/40329/2024 Department Commissioner Shri Narendra Challenge to dropping
                                         3



                             of Customs   Sharma              / reduction of penalty
                             Commissioner Shri Ashok          Challenge to dropping
11   C/40330/2024 Department
                             of Customs   Jain                / reduction of penalty
                             Commissioner Departmental        Challenge to dropping
12   C/40331/2024 Department
                             of Customs   Appeal              / reduction of penalty
                                          Shri Nerella
                                          Samueal             Challenge to
                             Commissioner
13   C/40333/2024 Department              Deepak              exoneration under
                             of Customs
                                          Avinash             114AA
                                          Appraiser
                             Commissioner Departmental        Challenge to dropping
14   C/40334/2024 Department
                             of Customs   Appeal              of penalty


     The appeals have been filed by exporters, their associated

     persons, Customs Broker, job workers and Customs officers,

     while the Department has filed appeals challenging non-

     imposition of penalty, incorrect invocation of statutory

     provisions and non-imposition of redemption fine. The facts

     being inter-connected, a consolidated narration is necessary.


     2.       The   case   originated       from   specific   intelligence

     developed by the Directorate of Revenue Intelligence that

     certain exporters were fraudulently exporting gold-plated

     copper jewellery as 22 carat gold jewellery with the intent to

     divert    duty-free   gold   procured     under   Notification     No.

     57/2000-Cus dated 08.05.2000. Acting on this intelligence,

     DRI intercepted and recalled an export consignment covered

     under Shipping Bill No. 7870940 dated 31.01.2022 filed by

     M/s. Shree Balaji Jewellers, declared as 22 carat gold

     jewellery. Examination of the consignment in the presence of

     independent witnesses, supported by XRF testing and assay

     at a BIS-recognised hallmarking centre, revealed that the

     goods were copper bangles coated with a thin layer of gold
                                     4



containing only about 7.5% to 10.35% gold. Investigation

further revealed that duty-free gold procured through HDFC

Bank, a nominated agency, was diverted to the domestic

market while fake jewellery was exported to falsely fulfil

export obligations. The manufacturing chain was traced to

M/s.     Ashok     Jewellers,    whose      proprietor       admitted    to

producing gold-coated copper bangles using only a fraction

of     the declared gold, thereby establishing the modus

operandi of diversion.



3.       The     investigation    has     clearly    brought     out    the

involvement        of   Customs     official        and    intermediaries,

especially examination of the consignment by a non-rostered

Appraiser and use of another officer's seal, as well as the

role    of   the    Customs      Broker     in   facilitating   such    an

examination.       Consequently,        statements        recorded   under

Section 108 corroborated these findings. Based on the

above,       a   show   cause     notice     was      issued    proposing

confiscation of fake jewellery, demand of duty on diverted

gold, and imposition of penalties under various provisions of

the Customs Act. The Adjudicating Authority, after due

process, confirmed confiscation and duty demand, imposed

penalties on the Exporter, Customs Broker, the non-rostered

Appraiser and associated personswhile dropping penalties

against HDFC Bank and certain other noticees.
                                 5




4.    Being aggrieved by the findings and conclusions

recorded in the impugned Order-in-Original, the Department,

HDFC, exporter, certain individuals, Customs Brokers and

other noticees have preferred the present appeals before this

Tribunal as detailed above.



5.    The Ld. Advocate Shri A.K. Jayaraj appeared on behalf

of the Assessees at Sl. Nos. 1, 2 and 6 of the Table. The Ld.

Advocates Shri C. Mohan, Shri M. Kumaresan and Ms.

Dhilshath, appeared for the Assessee at Sl. No. 8. The Ld.

Advocate Shri A. Ganesh appeared for the Assessee at Sl.

Nos. 4 and 13. The Ld. Advocate Shri Aliakbar Devjani

appeared on behalf of the Assessee at Sl. Nos. 5, 7 and 11.

Shri T. Sankara Kumar appeared in-person at Sl. No. 3. All

the Ld. counsels advanced detailed submissions in support of

their appeals and the cross-appeals filed by the Department.

The   Ld.    Authorized   Representative    Shri   Anoop   Singh

appeared for the Revenue and have ably defended the

impugned order.



6.    The Ld. Advocates appearing for the appellants in the

respective    appeals,    including   the    importer/exporter,

individuals, Customs Broker, and departmental officer, as

well as the Ld. Authorized Representative appearing for the
                                             6



Revenue in the cross-appeals, made detailed and elaborate

submissions. Since the appeals and cross-appeals arise out

of    a    common          investigation,       overlapping    facts,    and    a

composite        Order-in-Original,               their   submissions          are

summarised in a consolidated manner as under.



6.1       The appellants, in substance, submitted that the

impugned Order-in-Original suffers from serious infirmities in

law and on facts, is largely non-speaking, and confirms grave

civil and penal consequences without addressing the detailed

replies filed to the Show Cause Notice. It was contended that

the adjudicating authority has mechanically reproduced the

allegations from the Show Cause Notices and has failed to

analyse the defence submissions, documentary evidence,

and binding judicial precedents cited. According to the

appellants, such an approach violates the principles of

natural justice and renders the order unsustainable on this

ground alone.



6.2       In relation to the alleged export of fake gold jewellery,

the appellants contended that the entire case of the

Department           is    vitiated    by       serious   procedural     lapses,

including lack of a proper and unbroken chain of custody of

the       recalled        export      consignment,        absence       of   any

confirmation from foreign authorities regarding recall and
                                7



integrity of the parcel, and material discrepancies between

the description of goods in the Shipping Bill and the goods

allegedly examined at a later stage. It was argued that the

Shipping Bill has described the export goods as necklaces,

malas and chains, whereas the re-examined parcel contained

bangles, thereby creating a serious doubt as to whether the

same goods were examined at all. The appellants asserted

that in the absence of clear and unimpeachable evidence

establishing identity of goods, confiscation and penalties

cannot be sustained.



6.3   The appellants further submitted that the reliance

placed on statements recorded under Section 108 of the

Customs Act, 1962 is legally untenable and such statements

were either retracted, contradictory, or recorded under

coercive   circumstances,   and    in   any   event   were   not

corroborated by independent documentary or circumstantial

evidence. It was emphasised that settled law requires

corroboration of confessional statements, particularly when

they are used to fasten serious penal liability on co-noticees.

The appellants contended that statements of co-noticees

cannot be used as substantive evidence against other

noticees without independent corroboration.
                                      8



6.4   Specific submissions were advanced on behalf of the

Customs Broker, M/s. BSM Logistics, its CEO Shri A.

Mariappan,     and   its   partner       Shri    T.    Sankara       Kumar

contending that no specific charge was framed against the

Customs Broker as an entity in the Show Cause Notice, and

that the allegations, even if assumed to be true, were

confined to individuals. It was further contended that a

Customs Broker has no authority to choose, direct, or control

the posting or functioning of Customs officers, and that

routine   examination      of   cargo     by     an    Appraiser      or    a

Superintendent during peak workload cannot be construed as

abetment. The appellants asserted that there is no evidence

of mens rea, conspiracy, or intentional facilitation of export

of fake jewellery, which is a sine qua non for imposition of

penalty under Section 114 of the Customs Act.



6.5   On behalf of the individual appellants such as Shri

Sunil Sharma, Shri Narendra Sharma and Shri Ashok Jain, it

was contended that the findings against them are based on

presumptions, conjectures, and guilt by association. It was

argued    that   mere       family       relationship     or        business

acquaintance     cannot     substitute         for    proof    of     active

involvement, knowledge, or intentional participation in the

alleged   offence.   It    was    further        submitted      that       no

incriminating material was recovered from their premises, no
                                     9



money trail or hawala transaction was established, and no

independent witness was examined to prove their alleged

role in manufacture or export of fake jewellery.



6.6   With regard to HDFC Bank Ltd., appearing as a

respondent in the Department's appeal, it was vehemently

contended that the Bank, as a Nominated Agency under the

Foreign Trade Policy and Notification No. 57/2000-Cus., had

complied with every statutory obligation cast upon it. The

Bank submitted that it had no role whatsoever in the

manufacture, handling, or export of jewellery, and that its

obligations   were   limited   to       supply   of   duty-free   gold,

maintenance of records, submission of export documents,

and payment of duty in the event of non-export. It was

argued that compliance with conditions of the Foreign Trade

Policy is within the domain of DGFT and not Customs, and

that no finding of violation has been recorded by DGFT. The

Bank further submitted that duties in respect of non-

exported quantities were already paid through TR-6 challans,

bonds were cancelled by Customs, and therefore no further

demand can survive. The attempt of the Department to

impose vicarious liability on the Bank for the alleged criminal

acts of the exporter and certain Customs officer was

contended to be wholly impermissible in law.
                                        10



7.       The Ld. Authorized Representative Shri Anoop Singh,

Joint Commissioner has argued for the Revenue and his

submissions / arguments are as follows: -

7.1      That the impugned Order-in-Original is based on a

detailed    investigation     conducted         by   the    Directorate   of

Revenue Intelligence and is supported by scientific evidence,

expert     opinion,      documentary         records,      and   statements

recorded under Section 108 of the Customs Act, 1962. It was

contended that the adjudicating authority has correctly

appreciated the evidence in confirming confiscation, duty

demand and penalties against the principal offenders and

that such findings call for no interference.



7.2      The Revenue submitted that the investigation clearly

established       a    deliberate   and       well-planned       scheme   to

fraudulently export copper/brass jewellery with superficial

gold coating by misdeclaring the same as 22 carat gold

jewellery with inflated value, solely to falsely discharge

export obligation under Notification No. 57/2000-Cus. It was

argued     that       misdeclaration        stood    conclusively   proved

through physical examination, XRF analysis and assay

reports, which were not effectively rebutted by the exporter,

thereby attracting confiscation under Sections 113(i) and

113(ja) of the Customs Act.
                                       11



7.3   It was further contended that diversion of duty-free

gold into the domestic market is evident from the mismatch

between the quantity of gold procured and the gold actually

found in the exported jewellery, which cannot be explained

as normal process loss. The Revenue also relied upon the

statements recorded under Section 108, submitting that such

statements are admissible and retain evidentiary value

unless proved to be obtained under coercion, and that mere

retraction    does      not   dilute their probative value             when

corroborated by documentary and scientific evidence.



7.4   The Ld. Authorized Representative has further argued

that the role of various noticees, including the exporter,

intermediaries       and      the   Customs        Broker,    was    clearly

established       through     statements,         records    and    conduct,

showing active participation and facilitation of the fraudulent

exports.     It   was    submitted         that    the   Customs     Broker

consciously       deviated     from    prescribed        procedures     and

coordinated examination through a particular officer, while

departmental officers who permitted such deviation cannot

escape liability merely on the ground of departmental

proceedings, as statutory penalties under the Customs Act

operate independently.
                                    12



7.5     In respect of HDFC Bank Ltd., the Revenue contended

that as a nominated agency importing duty-free gold, it was

under a statutory obligation to ensure compliance with the

conditions of the exemption notification, and that once

diversion is established, duty liability arises under Section 28

irrespective of whether diversion was direct or through the

exporter. It was further argued that subsequent payment of

duty or cancellation of bond does not extinguish liability

arising from fraud, and that procedural lapses, if any, cannot

override     substantive   evidence.      The    Revenue    therefore

prayed for dismissal of the appeals filed by the appellants

and for allowing its cross-appeals by levying / restoring

penalties    and   liabilities   dropped    by    the     adjudicating

authority.



8.      We have carefully heard the submissions advanced by

all sides, perused the appeal records in detail, examined the

statutory provisions, considered the statements recorded

under    Section   108     of    the    Customs    Act,    1962,   the

documentary and scientific evidence recovered during the

course of investigation, as well as the written submissions

filed by the parties and the case laws cited.
                                   13



9.      Upon such comprehensive consideration of the factual

matrix and the applicable legal provisions, the following

issues arise for our determination in these appeals, namely:-

 i.    Whether exported goods were liable to confiscation.

ii.    Whether diversion of duty-free gold stands established.

iii.   Whether duty demand on HDFC Bank is sustainable.

iv.    Whether penalties imposed/dropped are legally correct.

v.     Whether   Revenue    Appeals    in   non    -imposition    of

       redemption fine on the Importer i.e., HDFC Bank merit

       acceptance



10.     We now proceed to consider the issues seriatim, as

they arise for determination, and record our findings thereon

in the paragraphs that follow: -



Issue No.      (i)Whether   exported goods        were   liable   to

confiscation

11.     The first and foremost issue that arises for our

determination is whether the goods exported by M/s Shree

Balaji Jewellers under Shipping Bill No. 7870940 dated

31.01.2022, declared as 22 CT plain gold jewellery, were

liable to confiscation under the provisions of Section 113 of

the Customs Act, 1962. This issue strikes at the very root of

the    controversy,   as    the    consequential    liabilities   of

confiscation, penalty, and allied proceedings flow from the

determination of this foundational question.
                                     14



12.      The factual matrix relevant to this issue is largely

undisputed.       The   consignment      in     question     was   initially

assessed and allowed for export, thereafter recalled based

on specific intelligence received by the Directorate of

Revenue Intelligence. Upon recall, the consignment was

subjected to detailed examination on 08.03.2022 in the

presence of independent witnesses, departmental officers,

and      a Government-approved           assayer.      The   examination

process involved physical inspection, scraping of samples,

XRF testing, and spectrometer analysis. The results of these

scientific tests form the bedrock of the Department's case.



13.      The   examination    categorically        revealed    that     the

consignment consisted of 375 bangles, whereas the Shipping

Bill and export documents described the goods as necklaces,

malas, and chains. This discrepancy in the very identity and

form of the exported goods is not a minor clerical or

interpretational difference but a fundamental variance going

to the nature of the goods themselves. Such a mismatch by

itself   raises   serious   doubt    about       the   veracity    of   the

declaration made at the time of export.



14.      More importantly, the scientific analysis established

that the average gold content of the examined jewellery was

approximately       8.74%,     with       the     balance      consisting
                                   15



predominantly of copper/brass. This is in stark contrast to

the declared purity of 22 carat gold (91.6%) of jewellery

exported. The magnitude of this variation is so substantial

that it cannot be attributed to trade tolerance, marginal

deviation, or manufacturing imperfection. Instead, it clearly

establishes that the goods were not gold jewellery of the

declared purity but were, in substance, imitation jewellery

with superficial gold plating and the fraud committed to

evade customs duty involved on imported gold.



15.    The declaration of the goods as 22 CT plain gold

jewellery      was    therefore   not   merely    inaccurate   but

demonstrably false. Such false declaration had a direct and

immediate nexus with the availment of benefits under

Notification    No.   57/2000-Cus,      which   permits   duty-free

import of gold subject to strict conditions, including the

requirement that the imported gold be used for manufacture

and export of gold jewellery of corresponding purity. The

mis-declaration was thus not accidental but was designed to

create an illusion of compliance with the notification.



16.    Section 113(i) of the Customs Act, 1962 provides that

goods shall be liable to confiscation if they are attempted to

be exported by means of mis-declaration in value or in any

material particular relating to description. Further, Section
                                   16



113(ja) covers cases where export goods are entered for

export by means of any false or incorrect declaration or

statement. In the present case, the mis-declaration pertains

to description, composition, purity, and value, all of which

are material particulars for the purposes of export and

eligibility under the exemption notification.



17.   The cumulative effect of the evidence on record leaves

no manner of doubt that the present case squarely falls

within the mischief contemplated under Sections 113(i) and

113(ja) of the Customs Act. The declaration was not only

incorrect but fundamentally deceptive, rendering the goods

liable to confiscation irrespective of whether the export

ultimately succeeded or not.



18.   The appellants have placed considerable emphasis on

alleged procedural infirmities, such as the recall of the

consignment, the sealing and resealing of packages, and the

absence of correspondence with Dubai Customs authorities.

We find these arguments to be devoid of any merit. It is well

settled that procedural lapses, unless shown to cause

prejudice or to vitiate the substantive evidence, cannot

override   clear   and   cogent        material   establishing   mis-

declaration.
                                 17



19.   In this regard, the law laid down by the Hon'ble

Supreme Court in Collector of Customs v. D. Bhoormull,

reported in 1983 (13) ELT 1546 (SC), is directly applicable.

The Supreme Court held that proceedings under the Customs

Act are civil in nature and that the Department is not

required to prove its case with mathematical precision or

proof beyond reasonable doubt. The test to be applied is one

of preponderance of probability, and circumstantial evidence

can be relied upon to establish smuggling or mis-declaration.



20.   Applying the above principle, once the Department

has established through scientific testing that the goods were

not what they were declared to be, the burden shifts to the

exporter to satisfactorily explain the discrepancies. In the

present case, no credible explanation has been offered as to

how goods declared as 22 CT gold jewellery were found to be

largely   composed   of   copper/brass.    The   deliberate    and

conspicuous silence of the exporter on this critical aspect

further strengthens the Department's case.



21.   The contention that absence of confirmation from

Dubai Customs or foreign authorities vitiates the confiscation

proceedings   is   also   unsustainable.   The   recall   of   the

consignment was admitted, the seals affixed by Customs

were found intact on 07.02.2022, and there is no evidence
                                     18



whatsoever to suggest that the consignment was tampered

with while in the custody of Customs. Mere conjecture or

hypothetical    doubt   cannot       displace     concrete   scientific

evidence.



22.      It is also pertinent to note that confiscation under

Section 113 does not depend upon the success or completion

of export. The attempt to export goods by mis-declaration

itself   attracts   confiscation.        This   position   has   been

consistently upheld in a catena of decisions, wherein it has

been held that once the attempt to export mis-declared

goods is established, confiscation follows as a natural

consequence.



23.      The Exporter's reliance on the argument of lack of

mens rea is misplaced at the stage of confiscation. Mens rea

is not a prerequisite for ordering confiscation of goods under

Section 113. The focus is on the nature of the goods and the

correctness of the declaration made to Customs. The

deliberate nature of mis-declaration, however, becomes

relevant for the purpose of penalty, which is addressed in

detail in succeeding paras of this order.



24.      We also take note of the fact that the value of the

goods was grossly inflated to align with the declared purity of
                                 19



22 CT gold. Such inflation of value is intrinsically linked to

the mis-declaration of purity and reinforces the conclusion

that the declaration was not bona fide.



25.    In view of the overwhelming evidence on record, the

statutory provisions, and the settled legal position governing

confiscation proceedings, we are of the considered opinion

that the exported goods were correctly held to be liable to

confiscation under Sections 113(i) and 113(ja) of the

Customs Act, 1962.



26.    We therefore uphold the findings of the Adjudicating

Authority on this issue and hold that the confiscation of the

goods covered under Shipping Bill No. 7870940 dated

31.01.2022 is legally valid, factually justified, and calls for no

interference.



Issue No. ii Whether diversion of duty-free gold stands

established.

27.    The second issue for our determination is whether the

duty-free gold imported under the benefit of Notification No.

57/2000-Cus dated 08.05.2000 was diverted instead of

being utilised for the manufacture and export of gold

jewellery, as mandated under the said notification and the

Foreign Trade Policy. This issue is distinct from the question
                                    20



of mis-declaration of export goods and relates to post-import

utilisation of duty-free inputs.



28.    The undisputed factual position emerging from the

records is that M/s Shree Balaji Jewellers procured a total

quantity of 9,364.86 grams of duty-free gold from HDFC

Bank, a nominated agency, during January 2022. Against

this   procurement,       the    exporter      claimed    to     have

manufactured and exported jewellery weighing 10,172.53

grams under Shipping Bill No. 7870940 dated 31.01.2022.

However,    scientific   examination     of   the   recalled    export

consignment    established      that    the   actual   gold    content

embedded in the jewellery was only 889.08 grams.



29.    Thus, there is an admitted and glaring shortfall of

8,475.78 grams of duty-free gold, for which no plausible or

verifiable explanation has been furnished. This quantitative

mismatch is not marginal or technical but substantial and

decisive, leading to a presumption of diversion unless

convincingly rebutted by the exporter.



30.    The primary explanation advanced by the exporter is

that the duty-free gold was sent to Kolkata for job work

through M/s Ashok Jewellers. However, this explanation

remains entirely unsupported by documentary evidence. No
                                      21



transport document such as lorry receipt or airway bill,

courier records, delivery challan, e-way bill, invoice or any

insurance document, or acknowledgment of receipt at the

job worker's premises have been produced. In matters

involving movement of high-value precious metal, such

absence of documentary trail assumes critical significance.



31.    The statements recorded from the alleged job workers

themselves further weaken the exporter's version. The

goldsmiths engaged at Kolkata have categorically stated that

the jewellery manufactured by them contained negligible

gold content and was largely composed of base metals. Their

statements corroborate the scientific findings and negate the

claim that duty-free gold bars were actually consumed in the

manufacturing process.



32.    It   is   also     relevant        that    no     stock   register,

manufacturing account, melting record, wastage statement,

or    reconciliation    statement         has     been     produced     to

demonstrate consumption of the duty-free gold. In schemes

involving   conditional     exemption,           maintenance     of   such

records is not optional but mandatory. The absence of these

records gives rise to a strong adverse inference against the

exporter.
                                22



33.   We find that the Notification No. 57/2000-Cus is a

conditional exemption notification, permitting import of gold

without payment of duty subject to strict compliance with

specified post-import conditions, foremost among them

being that the imported gold must be used for manufacture

and export of gold jewellery within the prescribed period. It

is settled law that exemption notifications of this nature must

be construed strictly, and the burden of proving compliance

squarely rests on the beneficiary.



34.   The Hon'ble Supreme Court in Commissioner of

Customs v. Dilip Kumar & Co., reported in 2018 (361) ELT

577 (SC), has authoritatively held that when an assessee

claims exemption under a notification, it is for the assessee

to strictly satisfy all conditions, and any ambiguity must be

resolved in favour of the Revenue. Applying this principle,

once the Department has shown non-utilisation of duty-free

gold for the intended purpose, the exemption is liable to be

denied.



35.   The appellants have argued that mere quantitative

mismatch cannot automatically lead to a finding of diversion

and that there must be direct evidence of sale in the

domestic market. We find this argument to be legally

untenable. Diversion, by its very nature, is often clandestine,
                                  23



and direct evidence of sale is rarely available. The law does

not   require     the   Department    to   prove    diversion   with

mathematical certainty or to trace the exact buyer in the

domestic market. Rather, it is incumbent on the part of the

exporter to properly account for the gold which was procured

from M/s. HDFC.



36.    Again, we are compelled to refer to the decision in

Collector of Customs v. D. Bhoormull, 1983 (13) ELT 1546

(SC), wherein the Hon'ble Supreme Court held that in cases

involving smuggling or clandestine activities, the Department

can   rely   on     circumstantial    evidence     and   reasonable

inferences drawn from proved facts. Applying the same

principle, when duty-free gold is shown to be unaccounted

for and not reflected in the exported product, diversion can

be legitimately inferred.



37.    The exporter's contention that the gold was not

physically seized and therefore cannot be confiscated is also

misconceived. Section 111(o) of the Customs Act provides

for confiscation of goods imported subject to a condition,

when such condition is violated. The violation in the present

case is complete once the gold is not utilised for the

prescribed export purpose.
                                   24



38.   The argument advanced on behalf of HDFC Bank that

the diversion, if any, is attributable solely to the exporter

and cannot be visited upon the nominated agency is

addressed separately under Issue No. (iii) & (v). For the

limited purpose of the present issue, the focus is on whether

diversion occurred at all. On this aspect, the evidence

overwhelmingly establishes that the duty-free gold did not

form part of the exported jewellery and diversion of gold

stands established.



39.   The appellants have also contended that reconciliation

based on purity analysis is flawed and that manufacturing

loss and wastage must be factored in. We find this

contention    to   be   devoid    of   merit.   Even   allowing   for

reasonable wastage, the difference between 9,364.86 grams

and   889.08       grams   is    far   beyond    any    conceivable

manufacturing loss. No industry standard or expert evidence

has been produced to justify such an abnormal depletion.



40.   The cumulative effect of the quantitative mismatch,

absence      of    transport     and     manufacturing     records,

corroborative statements of job workers, and scientific

analysis of the exported jewellery leaves no room for doubt

that the imported duty-free gold was not utilised for the
                                      25



intended export and was instead diverted in violation of the

conditions of Notification No. 57/2000-Cus.



41.     We therefore hold that the diversion of 8,475.78

grams of duty-free gold stands conclusively established. The

denial of exemption, coupled with confiscation of the diverted

quantity under Section 111(o) of the Customs Act, 1962, is

legally sound and fully justified.



42.     Accordingly, we affirm the findings of the Adjudicating

Authority on this issue and uphold the order of confiscation

of the diverted gold under Section 111(o), while sustaining

the decision not to impose redemption fine due to non-

availability of the goods.



ISSUE No. (iii): Whether the Duty Demand on HDFC Bank Is

Sustainable

43.     The present issue about the sustainability of the

customs    duty    demand         raised    against   HDFC    Bank,   a

nominated agency importer under Notification No.57/2000-

Cus, and the Department's challenge to the findings of the

adjudicating authority insofar as the adjudicating authority

held that the case would fall under Section 28(1) and not

under    Section   28(4)     of    the     Customs    Act,   1962. The

Department has further challenged the non-imposition of

penalties upon HDFC Bank on the ground that the duty-free
                                  26



gold imported by the Bank ultimately stood diverted into the

domestic market through fraudulent export transactions

undertaken by M/s Shree Balaji Jewellers.



44.    From the impugned Order-in-Original, it emerges that

HDFC Bank had imported duty-free gold bullion under

Notification    No.57/2000-Cus    under     the   "Export   Against

Supply by Nominated Agencies" Scheme and supplied the

same to M/s Shree Balaji Jewellers against export-linked

documentation and security mechanisms contemplated under

the Foreign Trade Policy, Handbook of Procedures and

Circular No.27/2016-Cus dated 10.06.2016. The allegation of

the Department is that instead of manufacturing and

exporting genuine gold jewellery, the exporter diverted the

duty-free gold into the domestic market and fraudulently

exported       gold-plated   copper/brass     jewellery     through

fabricated shipping bills and false export documentation.



45.    The adjudicating authority has specifically recorded

that upon detection of non-fulfillment of export obligation

and diversion of duty-free gold, HDFC Bank discharged the

entire customs duty together with applicable interest even

prior to issuance of the Show Cause Notice. The records

establish that customs duty amounting to Rs.66,45,643/-

together with interest of Rs.4,27,399/- stood paid through
                                       27



TR-6 challans dated 08.06.2022 and 09.06.2022, whereas

the Show Cause Notice came to be issued only subsequently

on 04.02.2023. The adjudicating authority appropriated the

said amounts and further recorded absence of collusion,

wilful suppression or conscious involvement on the part of

HDFC Bank in the fraudulent exports undertaken by the

exporter.



46.     The Departmental Appeal however proceeds on the

footing     that    once    export    obligation     stood        fraudulently

violated,    the     nominated       agency      importer        automatically

became liable not only for customs duty but also for

invocation of Section 28(4) of the Customs Act, 1962.

According to the Department, the expression "either by itself

or    through       other   exporters"      occurring       in     Notification

No.57/2000-Cus fastens ultimate responsibility upon the

nominated       agency      importer       for   fulfillment       of    export

obligation and consequently the fraud committed by the

exporter becomes attributable to the importer itself.



47.     We are unable to accept the aforesaid contention in

the broad manner canvassed by the Department. Notification

No.57/2000-Cus undoubtedly casts obligations upon the

nominated          agency   importer       and     specifically         requires

execution of bonds, undertaking to export jewellery either by
                                      28



itself or through exporters within the stipulated period. The

notification further binds the importer to pay customs duty

on    the   quantity   representing          the   shortfall   in    export

obligation. Circular No.27/2016-Cus correspondingly provides

that where proof of export is not produced within the

prescribed period, the nominated agency shall deposit the

customs duty together with applicable interest. The FTP and

Handbook of Procedures similarly contemplate recovery of

customs duty from the nominated agency importer in the

event of export default. Thus, the statutory framework

clearly creates a recovery mechanism founded upon the

exemption      notification,   FTP        obligations   and    the    bond

executed before Customs authorities.



48.    We find that the Coordinate Bench of the CESTAT,

New Delhi in M/s HDFC Bank Ltd. v. Commissioner of

Customs (Adjudication), Delhi Zone, Final Order Nos.51571-

51574/2025 dated 09.10.2025 [2025 (10) TMI 825 - CESTAT

NEW DELHI], while dealing with an identical controversy

arising     under   Notification     No.57/2000-Cus,           extensively

examined the legal framework governing duty-free gold

imports by nominated agencies. The Coordinate Bench relied

upon the decisions of the Hon'ble Supreme Court in Munjal

Showa Ltd. v. Commissioner of Customs & Central Excise,

2009 (246) E.L.T. 18 (S.C.) and Afloat Textiles (India) Pvt.
                                     29



Ltd. v. Union of India, 2009 (235) E.L.T. 587 (S.C.) and

reiterated the settled principle that exemption notifications

operating     through      export     obligation        schemes     create

independent statutory obligations enforceable through bonds

and undertakings executed before Customs authorities and

that recovery of customs duty upon breach of export

obligation   fundamentally        flows   from the terms            of the

notification and the bond conditions themselves.



49.     In Munjal Showa Ltd., (Supra) the Hon'ble Supreme

Court recognized that where an exemption notification is

conditional in nature and operates through execution of

bonds securing export obligations, the liability to discharge

customs duty upon breach of such conditions flows directly

from the statutory undertaking executed by the importer and

the exemption notification itself. Similarly, in Afloat Textiles

(India) Pvt. Ltd., (Supra) the Hon'ble Supreme Court

emphasized     that      export   obligation      schemes     under the

Foreign     Trade   Policy    constitute      a    complete    statutory

framework and that obligations arising thereunder remain

enforceable through the bonds and undertakings executed

under the scheme. Relying upon the aforesaid principles, the

Coordinate Bench held that the nominated agency importer

under     Notification     No.57/2000-Cus          remains    liable    to

discharge    customs       duty     through       the   statutory    bond
                                       30



mechanism once export obligations fail, irrespective of the

subsequent conduct of the exporter.



50.     The Coordinate Bench however simultaneously drew a

clear distinction between enforcement of statutory duty

liability   arising    under    the     exemption       notification     and

invocation of fraud-based proceedings under Section 28(4)

and the penal provisions of the Customs Act. The Tribunal

categorically held that while recovery of customs duty may

independently arise under the notification, FTP framework

and     bond     obligations,     fraud,         suppression   or      wilful

misstatement         cannot    automatically       be   imputed     to   the

nominated agency importer merely because the exporter

subsequently committed fraud. The Tribunal specifically

observed that once the nominated agency had deposited the

customs duty together with applicable interest prior to

issuance of the Show Cause Notice and the corresponding

bond obligations stood discharged, "the matter should have

ended there" insofar as substantive revenue recovery was

concerned.



51.     We find that the ratio of the aforesaid Coordinate

Bench decision squarely applies to the facts of the present

case. The records before us clearly establish that HDFC Bank

imported       the    gold     within      the     statutory   framework
                                          31



contemplated under Notification No.57/2000-Cus, Circular

No.27/2016-Cus, FTP and HBP; executed the prescribed

bonds;     released           bullion    only     against       export-linked

documentation;          and     upon     detection    of    export     default,

discharged the entire customs duty together with applicable

interest through the bond mechanism even prior to issuance

of the Show Cause Notice. The adjudicating authority itself

has categorically recorded that no evidence exists showing

collusion, fabrication of documents, manipulation of export

process,    or      conscious      participation      by   HDFC       Bank    in

diversion of duty-free gold.



52.    It is also significant that Section 28(2) of the Customs

Act,   1962,      as     applicable      during    the     relevant    period,

specifically contemplated that where the person chargeable

with duty voluntarily pays the duty together with applicable

interest    and        informs     the    proper      officer    in    writing,

proceedings in respect of such duty and interest stand

concluded      to      that    extent.    In    the   present     case,      the

Department itself quantified the duty liability through the

bond mechanism and accepted payment of the entire

customs duty together with applicable interest prior to

issuance of the Show Cause Notice. The substantive revenue

liability arising under Notification No.57/2000-Cus, FTP, HBP,

Circular No.27/2016-Cus and the executed bonds therefore
                                    32



already stood fully discharged even before commencement

of adjudicatory proceedings.



53.   The Department's reliance upon Section 28(4) is

therefore misconceived. The allegations against HDFC Bank

at the highest relate to alleged failure to detect or prevent

the subsequent fraud committed by the exporter. Such

allegations, even if assumed, cannot by themselves satisfy

the stringent jurisdictional ingredients of collusion, wilful

suppression    or    intentional   misstatement     necessary   for

invocation    of    Section   28(4).    The   distinction   between

statutory recovery liability flowing from the exemption

notification and quasi-criminal consequences flowing from

fraud-based provisions cannot be obliterated in the manner

suggested by the Department.



54.   There is no dispute that the nominated agency

importer remains liable to discharge customs duty where

export obligation fails. In fact, HDFC Bank has already

discharged the entire customs duty together with interest

under the statutory mechanism contemplated by Notification

No.57/2000-Cus, Circular No.27/2016-Cus and the executed

bonds. Once the entire substantive duty liability together

with applicable interest already stood discharged prior to

issuance of the Show Cause Notice itself, no surviving
                                    33



dispute regarding recovery of customs duty substantially

remained for adjudication before us insofar as HDFC Bank is

concerned. The question of penalties and other consequential

liabilities are being separately dealt with in the later portion

of this order.



55.    Consequently,     the   findings    recorded    by    the

adjudicating authority treating the case as one falling under

Section 28(1) and not under Section 28(4) call for no

interference. The Departmental Appeal on this issue is

therefore liable to be rejected.



ISSUE No. (iv): Whether the Penalties Imposed, Dropped,

or Not imposed upon the various noticees are legally

Sustainable

56.    The fourth issue for determination concerns the

correctness, legality, proportionality, and sustainability of the

penalties imposed by the Adjudicating Authority upon various

noticees as also the legality of dropping or non-imposition of

penalties against certain noticees, which has been challenged

by the Department. The issue requires an independent

evaluation of the role, conduct, degree of involvement, and

mens rea attributable to each category of noticee in the light

of the statutory requirements under Sections 112, 114,

114AA and 117 of the Customs Act, 1962.
                                34



(A) Penalties on Exporter - M/s. Shree Balaji Jewellers and

Shri Sunil Sharma (Noticee Appeal No. C/40543/2024)

57.1   At the outset, it is necessary to note that M/s Shree

Balaji Jewellers is a proprietary concern of Shri Sunil Sharma

and therefore the proprietary concern and the proprietor are

not distinct legal entities for the purpose of adjudication

under the Customs Act, 1962. Consequently, the acts,

declarations, omissions, and liabilities attributable to Shri

Sunil Sharma as proprietor are intrinsically attributable to

M/s Shree Balaji Jewellers itself. Accordingly, the penalties

imposed upon Shri Sunil Sharma are deemed to operate

against the proprietary concern M/s Shree Balaji Jewellers as

well, the proprietary concern having acted only through its

sole proprietor Shri Sunil Sharma.



57.2   As   regards   M/s.   Shree   Balaji   Jewellers   and   its

proprietor Shri Sunil Sharma, the record clearly establishes

deliberate misdeclaration, false representation of gold purity,

and attempted export of goods fundamentally different from

those declared in the export documents. The impugned

Order-in-Original records that the consignments declared as

"22 CT plain gold jewellery" including necklace and haram

were, upon examination and scientific testing, found to be

copper/brass articles with superficial gold coating. The export

documents including shipping bills, invoices and declarations

originated from M/s. Shree Balaji Jewellers under the control
                                    35



and authority of Shri Sunil Sharma and the misdeclaration

arose at the very source of export documentation. Penalties

were accordingly imposed upon M/s. Shree Balaji Jewellers

and Shri Sunil Sharma under Sections 114(iii), 114AA and

112(ii) of the Customs Act, 1962.



58.   The misdeclaration in the present case is not confined

to valuation or minor compositional variation but extends to

the very identity and nature of the exported goods. The

evidence on record establishes that Shri Sunil Sharma, being

the proprietor and controlling person of the exporting entity,

was directly responsible for procurement, presentation,

declaration    and   attempted          export    of    the      impugned

consignments. The role attributed to him is therefore central

to the fraudulent scheme involving diversion of duty-free

gold and attempted discharge of export obligations through

export of fake jewellery.



59.   Section    114(iii)      applies    where        goods     liable   to

confiscation   are   knowingly        attempted        to   be   exported

improperly, while Section 114AA penalises knowing use of

false declarations and documents. The shipping bills, invoices

and   declarations     filed     by      the     exporter        contained

demonstrably false particulars relating to purity, composition

and nature of the exported goods. The evidence further
                               36



establishes nexus between export of fake jewellery and

diversion of duty-free imported gold obtained under the

exemption scheme. The cumulative circumstances therefore

establish deliberate abuse of the export promotion scheme

and conscious use of fabricated export declarations.



60.   The    Hon'ble   Supreme     Court   in   Collector   v.   D.

Bhoormull, 1983 (13) E.L.T. 1546 (S.C.), has held that in

customs matters mens rea can legitimately be inferred from

conduct and surrounding circumstances. Applying the said

principle, the sustained pattern of misdeclaration and use of

fabricated   export    declarations    conclusively     establish

conscious involvement on the part of the exporter. We

therefore find no reason to interfere with the findings or

penalties imposed in the impugned Order-in-Original against

M/s. Shree Balaji Jewellers and Shri Sunil Sharma and

consequently Noticee Appeal No. C/40543/2024 is liable to

be dismissed.



(B) Penalties on Shri Narendra Sharma (Noticee Appeal No.

C/40544/2024)

61.   Shri Narendra Sharma has contended that he neither

physically handled the export consignments nor participated

in preparation of export documents and that the allegations

against him are founded merely on acquaintance with the

exporter. We are unable to accept the said contention.
                                    37




62.      The   impugned    Order-in-Original           records   specific

findings regarding the active involvement of Shri Narendra

Sharma in coordinating operational aspects of the export

activity undertaken through M/s. Shree Balaji Jewellers. The

investigation revealed that he acted as a vital link between

the exporter, intermediaries and persons connected with

manufacture and movement of the impugned consignments.

The statements recorded during investigation, call detail

records and surrounding circumstances establish that he was

actively involved in arranging and facilitating the export

process and was not a peripheral participant.



63.      The contention that penal liability under Section 114

requires physical handling of goods or direct filing of export

documents is legally untenable. Section 114(iii) specifically

covers     acts   of   abetment,        facilitation   and   intentional

assistance rendering export goods liable to confiscation. In

Jeena & Co. v. Additional Collector, 1992 (58) E.L.T. 276

(Tri.), it was held that active facilitation or assistance in the

offending transaction, even without direct execution of

export formalities, is sufficient to sustain penalty. Applying

the above principles, we are satisfied that the cumulative

evidence on record clearly establishes conscious facilitation
                               38



and operational involvement on the part of Shri Narendra

Sharma in the fraudulent export scheme.



64.   We therefore find no infirmity in the findings recorded

in the impugned Order-in-Original insofar as Shri Narendra

Sharma is concerned. The penalty imposed upon him under

Section 114(iii) of the Customs Act, 1962 is justified,

proportionate and legally sustainable.



(C) Departmental Appeal insofar as Shri Narendra Sharma

is concerned (Appeal No. C/40542/2024)

65.   The grievance of the Revenue is that the adjudicating

authority, despite recording findings that Shri Narendra

Sharma orchestrated the offending transactions by roping in

Shri Sunil Sharma of M/s. Shree Balaji Jewellers and Shri A.

Mariappan of M/s. BSM Logistics, failed to impose penalties

under Sections 114AA and 112(ii) of the Customs Act, 1962.



66.   However, insofar as penalty under Section 112(ii) is

concerned, we find that the evidence against Shri Narendra

Sharma principally relates to facilitation and coordination of

export activities and not to direct dealing with the imported

duty-free gold alleged to have been diverted. No recovery of

imported gold was effected from him and no material has

been produced establishing that he physically dealt with,

possessed, transported, concealed, or handled imported gold
                                      39



liable to confiscation under Section 111 of the Customs Act,

1962. While the cumulative circumstances clearly justify

penalties relating to the fraudulent export and use of false

declarations,    the     evidentiary      threshold         necessary      for

sustaining penalty under Section 112(ii) is not satisfied.

Accordingly, penalty under Section 112(ii) is held not

invocable against Shri Narendra Sharma.



67.      As regards, penalty under section 114AA of Customs

Act, we have examined the contentions of the Department.

The evidentiary record clearly establishes that Shri Narendra

Sharma     was    not    a   peripheral       participant     but     a   key

operational coordinator in the execution of the fraudulent

export scheme involving diversion of duty-free gold and

export    of   fake    jewellery    under     cover    of    false    export

documentation. The materials on record, including the

statements       of     co-noticees          and      the     surrounding

circumstances,        demonstrate      his    active    involvement         in

coordinating     the    exporter,     intermediaries        and      customs

clearance process. Though the export documents may have

been physically filed through the exporter and Customs

Broker,    the   cumulative        evidence    establishes        that    Shri

Narendra Sharma consciously facilitated and caused the use

of materially false declarations and export documents in the

course of customs business. The export documents, invoices
                                   40



and    declarations      describing    gold-plated    copper/brass

jewellery as "22 CT plain gold jewellery" were knowingly

used in customs proceedings for obtaining export clearance

and fulfillment of obligations under Notification No.57/2000-

Cus. Section 114AA is not confined only to the person who

physically prepares or signs the false declaration, but

extends to any person who knowingly uses or causes such

false declarations or documents to be used. In the present

case, the fraudulent exports and the use of false export

declarations formed an integral part of the coordinated

scheme in which Shri Narendra Sharma played a significant

and conscious role. The cumulative evidence therefore

establishes conscious and intentional use and facilitation of

materially false declarations attracting Section 114AA of the

Customs Act, 1962

We    therefore   hold    that   the   ingredients   necessary   for

invocation of Section 114AA stand satisfied against Shri

Narendra Sharma. We therefore impose a penalty of Rs

20,00,000/- on Narendra Sharma under Section 114AA of

Customs Act 1962 as imposed in the case of Shri Sunil

Sharma.



68.    Accordingly, while we uphold the penalty imposed

upon Shri Narendra Sharma under Section 114(iii), we also

hold that penalty under Section 114AA of the Customs Act,
                                41



1962 is legally sustainable against him. However, penalty

under Section 112(ii) is held not invocable. Consequently,

the connected Departmental appeal is partly allowed to the

above extent.



(D) Penalties on Shri Ashok Jain (Noticee Appeal No.

C/40545/2024)

69.     Shri Ashok Jain has contended that he was neither the

exporter nor the importer and that his association with

manufacture     of   jewellery does    not   establish   conscious

involvement in export fraud or diversion of duty-free gold.



70.     On careful examination of the impugned Order-in-

Original, we find that Shri Ashok Jain has been specifically

identified as one of the principal operational persons involved

in arranging manufacture and movement of fake jewellery

ultimately exported in the guise of genuine 22-carat gold

jewellery. The Order-in-Original records that the gold-plated

copper jewellery was manufactured through job workers

under    his   supervision   and    instructions   and   that   he

maintained continuous coordination with the exporter and

associated persons involved in the export chain.



71.     The plea that Shri Ashok Jain did not personally file

shipping bills or physically present the goods before Customs

does not absolve him from liability under Section 114(iii)
                                     42



once active facilitation and intentional assistance stand

established. The cumulative evidence discussed in the Order-

in-Original, including statements of job workers, linkages

with exporter entities and coordination in movement of

consignments, sufficiently establishes conscious involvement

on his part in the fraudulent export scheme.



72.     The     reliance   placed    upon      decisions     concerning

absence of mens rea does not advance the appellant's case

because       the   present    matter      involves    sustained    and

coordinated activity relating to manufacture and export of

fake jewellery under cover of export promotion benefits.

Applying the ratio laid down in Collector v. D. Bhoormull and

Jeena    &    Co.   (Supra),   we    hold     that    the   surrounding

circumstances and cumulative evidence sufficiently establish

intentional facilitation and abetment.



73.     We therefore concur with the findings recorded in the

impugned        Order-in-Original        regarding    the    role   and

involvement of Shri Ashok Jain and hold that the penalty

imposed upon him under Section 114(iii) of the Customs Act,

1962 is legally sustainable and proportionate to the gravity

of the offence.



(E) Departmental Appeal insofar as Shri Ashok Jain is

concerned (Appeal No. C/40541/2024)
                                 43



74.      The grievance of the Revenue is that the adjudicating

authority, despite recording findings regarding the active role

played by Shri Ashok Jain in arranging manufacture and

movement of fake jewellery, failed to impose penalty under

Section 112(ii) of the Customs Act, 1962.



75.      We have carefully examined the above contention.

The materials on record clearly establish that Shri Ashok Jain

played     an   important    operational   role   in   arranging

manufacture of gold-plated fake jewellery and coordinating

movement of such goods for export under the guise of

genuine gold jewellery. However, the evidence principally

relates to manufacture and movement of fake jewellery

intended for export and not to direct handling, possession,

concealment or disposal of imported duty-free gold bars.



76.      No recovery of imported gold bars was effected from

Shri   Ashok    Jain and    no material    has been produced

establishing that he physically dealt with or possessed

imported duty-free gold liable to confiscation under Section

111 of the Customs Act. The distinction between facilitation

of fraudulent export and direct dealing with imported goods

assumes significance in the context of Section 112(ii). While

the evidence sufficiently establishes the former, it falls short

of conclusively establishing the latter.
                                  44




77.   Accordingly, while we uphold the penalty imposed

upon Shri Ashok Jain under Section 114(iii), we do not find

sufficient legal or evidentiary basis to interfere with the

adjudicating authority's decision insofar as non-imposition of

penalty under Section 112(ii) is concerned. The connected

Departmental appeal therefore stands rejected.



(F) Penalties on Customs Broker: M/s. BSM Logistics, Shri

A. Mariappan and Shri T. Sankara Kumar (Noticee Appeals

Nos. C/40546/2024, C/40547/2024 and C/40548/2024)




78.   We shall now examine the appeals filed by M/s. BSM

Logistics, licensed Customs Broker, Shri A. Mariappan, CEO

of M/s. BSM Logistics, and Shri T. Sankara Kumar, Partner of

the said Customs Broker firm, challenging the penalties

imposed upon them under Section 114(iii) of the Customs

Act, 1962 in terms of the impugned Order-in-Original No.

32/2024-AIR dated 03.02.2024 passed by the Principal

Commissioner     of   Customs,        Air    Cargo,   Chennai.    The

consistent contention advanced by the appellants is that they

merely acted in the ordinary course of customs clearance

activities as licensed Customs Brokers and that no evidence

exists to establish conscious involvement, mens rea, or

intentional facilitation of export of fake jewellery. It has

further   been   contended   that           the   appellants   neither
                                         45



manufactured         the    jewellery        nor    had    any    knowledge

regarding the alleged substitution of gold jewellery with gold-

plated copper articles.



79.      We have carefully examined the findings recorded in

the impugned Order-in-Original, the evidentiary materials

relied   upon by the           Department,          and    the submissions

advanced on behalf of the appellants. A Customs Broker

licensed under the Customs Brokers Licensing Regulations

occupies a position of trust within the customs clearance

mechanism and functions as a crucial interface between

importers/exporters and the Customs Department. Such a

licensed intermediary is expected to maintain heightened

standards of diligence, neutrality, and adherence to statutory

safeguards, particularly in transactions involving export of

sensitive commodities such as gold jewellery exported under

duty exemption schemes.



80.      The   impugned           Order-in-Original        records    specific

findings that M/s. BSM Logistics and its key personnel

consciously         facilitated       examination         of   the     export

consignments         through      a    particular    officer     despite   the

existence      of     a    roster      system       governing        jewellery

examination. The adjudicating authority has noted that the

examination of the impugned consignments was repeatedly
                               46



routed through Shri N.S.D. Avinash, who was not rostered as

the Jewellery Examiner on the relevant dates, and that such

routing was facilitated through the active involvement and

coordination of the Customs Broker firm and its personnel.

The materials on record, including statements recorded

under Section 108 of the Customs Act, reveal admissions

regarding repeated routing of consignments and coordination

of examination procedures outside the prescribed roster

discipline.



81.    The conduct attributed to the Customs Broker and its

personnel cannot be brushed aside as mere procedural

convenience or routine discharge of brokerage functions. The

roster system governing examination of jewellery exports is

not an empty formality but an institutional safeguard

intended to ensure transparency and integrity in customs

examination of sensitive export consignments involving

precious metals. Conscious deviation from such safeguards

by repeatedly routing consignments through a non-rostered

officer directly facilitated the fraudulent export of mis-

declared goods. The cumulative circumstances therefore

establish active facilitation and conscious assistance in the

process by which fake jewellery passed through customs

control under the guise of genuine 22-carat gold jewellery.
                                   47



82.   The Ld. Counsel for the appellants has relied upon

Fast Cargo Movers v. Commissioner of Customs [2018 (362)

E.L.T. 184 (Tri.-Del.)], Guru Ispat Ltd. v. CCE [2003 (151)

E.L.T. 384 (Tri.-Kol.) affirmed at 2003 (157) E.L.T. A87

(S.C.)], Sawroop Shipping Services v. Commissioner of

Customs       [2008    (227)      E.L.T.   555    (Tri.-Chennai)],

Commissioner v. Vaz Forwarding Ltd. [2011 (266) E.L.T. 39

(Guj.)], and Jeena & Co. v. Additional Collector [1992 (58)

E.L.T. 276 (Tri.)] to contend absence of mens rea and to

argue that intermediaries such as Customs Brokers cannot

be penalised in the absence of direct evidence showing

knowledge of the offending transaction. There can be no

dispute regarding the legal proposition laid down in the

aforesaid decisions that penalty cannot be imposed in cases

involving mere routine discharge of statutory functions

without evidence of conscious involvement or facilitation.



83.   However, we find that the said decisions are clearly

distinguishable on facts. In the present case, the evidence

does not disclose passive or routine compliance with customs

formalities    but    indicates    conscious     coordination   of

examination through a non-rostered officer and repeated

facilitation of deviation from prescribed safeguards in relation

to sensitive exports linked to duty-free gold. Even assuming

reliance is placed on the decision of the Tribunal in Fast
                                            48



Cargo Movers v. Commissioner of Customs, 2018 (362)

E.L.T. 184 (Tri.-Del.), the same does not advance the case of

the   appellants,       as    it   neither        lays   down      an     absolute

proposition that intermediaries can never be penalised nor

does it override the binding law declared by the Hon'ble

Supreme        Court.    In    Fast     Cargo        Movers,    the       Tribunal

specifically found absence of prior knowledge, conscious

facilitation, or intentional aid and further recorded that there

was no allegation regarding manipulation of examination

procedure, selection of officers, or bypassing of institutional

safeguards. The present case stands on an entirely different

footing,   where        the    evidence          establishes    positive       acts

facilitating    circumvention         of        statutory   controls      through

coordinated routing of consignments for examination outside

the roster mechanism.



84.    In the above factual and legal background, we are of

the considered view that the findings recorded in the

impugned        Order-in-Original               regarding    the        role   and

involvement of M/s. BSM Logistics, Shri A. Mariappan and

Shri T. Sankara Kumar do not suffer from any infirmity

warranting interference by this Tribunal. The cumulative

evidence       on   record         sufficiently      establishes        conscious

facilitation and active assistance in the export of misdeclared

goods rendering the consignments liable to confiscation
                                  49



under Section 113 of the Customs Act, 1962. The penalties

imposed upon M/s. BSM Logistics, Shri A. Mariappan and

Shri T. Sankara Kumar under Section 114(iii) of the Customs

Act, 1962 are therefore legally sustainable, proportionate to

the gravity of the misconduct established on record, and

liable to be confirmed. Consequently, Noticee Appeal Nos.

C/40546/2024, C/40547/2024 and C/40548/2024 are liable

to be dismissed and the penalties imposed in the impugned

Order-in-Original No. 32/2024-AIR dated 03.02.2024 passed

by the Principal Commissioner of Customs, Air Cargo,

Chennai are upheld.



(G)   Penalties   on    Departmental    Officer   -   Shri   N.S.D.

Avinash, Appraiser, (Noticee Appeal C/40365/2024)

85.      The next aspect requiring examination concerns the

sustainability and extent of penalties imposed or proposed

against departmental officers despite findings regarding

procedural deviation and facilitative conduct in the export

clearance process. It is settled law that public office does not

confer    immunity     from   penal   consequences     under   the

Customs Act where acts or omissions facilitate export of

goods liable to confiscation. Sections 112 and 114 apply to

"any person" and do not carve out any blanket exception in

favour of departmental officers. At the same time, the

degree of culpability necessary for invoking each penal
                                   50



provision     must   independently     satisfy   the   statutory

ingredients prescribed therein.



86.      The Ld. Counsel for Shri N.S.D. Avinash has relied

upon Boria Ram v. Commissioner of Customs [2005 (190)

E.L.T.      496   (Tri.-Del.)],    Ruchika   International    v.

Commissioner of Customs [2006 (198) E.L.T. 360 (Tri.-

Del.)], A.P. Sales v. Commissioner of Customs [2007 (216)

E.L.T. 161 (Tri.-Del.)], Hargovind Exports v. Commissioner of

Customs [2010 (259) E.L.T. 362 (Tri.-Del.)], Commissioner

v. M. Vasi [2015 (325) E.L.T. 255 (Mad.)], Fast Cargo

Movers v. Commissioner of Customs [2018 (362) E.L.T. 184

(Tri.-Del.)], Gobinda Das v. Commissioner of Customs [2017

(352) E.L.T. 583 (Tri.-Kol.)] and G-Tech Industries v. Union

of India [2016 (339) E.L.T. 209 (P&H)] to contend that

negligence or procedural lapse cannot by itself amount to

abetment. There can be no dispute regarding the legal

proposition laid down in the aforesaid decisions. However,

those cases arose in factual situations where officers acted

within the scope of assigned duties without evidence of

conscious procedural deviation, misuse of official authority,

or facilitation of export contrary to statutory safeguards.



87.      From the records, it is evident that Shri N.S.D.

Avinash examined the export consignment covered under
                               51



Shipping Bill No. 7870940 dated 31.01.2022 despite not

being rostered as the Jewellery Examiner on the relevant

date. The examination was conducted in clear deviation from

prescribed roster instructions and established examination

protocol. The goods physically presented for examination

were   gold-coated   copper   bangles   whereas   the   export

documents described the goods as "22 CT plain gold

jewellery" including necklace and haram. The discrepancy

was apparent even on ordinary visual inspection. Despite

such discrepancy, the consignment was facilitated for export

by use of official endorsement and examination seal.

Conscious deviation from prescribed safeguards by a non-

rostered officer undertaking examination through use of

official authority cannot be brushed aside as a mere

procedural lapse or innocent error of judgment.



88.    The appellant Shri N.S.D. Avinash has further relied

upon Commissioner of Customs, New Delhi v. M.I. Khan

reported in 2000 (120) E.L.T. 542 and the judgment of the

Hon'ble Supreme Court in Costao Fernandes v. State

reported in 1996 (84) E.L.T. 577 (S.C.) to contend that

protection under Section 155 of the Customs Act extends to

officers discharging official functions. We are unable to

accept the said contention in the factual context of the

present case. The decisions in M.I. Khan and Costao
                                     52



Fernandes arose in situations where the acts attributed to

the officers were intrinsically connected with bona fide

discharge of official functions and where no evidence existed

of conscious facilitation or deliberate procedural deviation. In

the present matter, however, the evidence specifically

discloses examination of export consignments by a non-

rostered officer, use of official endorsement contrary to

roster discipline, and facilitation of export clearance despite

obvious     discrepancy     between        declared   description    and

physical nature of goods. The controversy therefore extends

beyond mere erroneous discharge of official duty and enters

the realm of conscious procedural deviation facilitating

export of misdeclared goods. Consequently, the statutory

protection under Section 155 of the Customs Act cannot, in

the facts of the present case, be extended to exclude

examination of penal liability under the Customs Act where

conscious procedural deviation facilitating export of mis-

declared goods is prima facie established. This is particularly

so when the very manner of discharge of official functions

forms     part   of   the   facilitative   conduct    alleged   by   the

Department



89.     In the above factual background, we are of the

considered view that the cumulative circumstances on record

establish conscious disregard of statutory safeguards and
                                   53



active facilitation of export of mis-declared goods rendering

the export consignments liable to confiscation. The conduct

of Shri N.S.D. Avinash therefore squarely attracts penalty

under Section 114(iii) of the Customs Act, 1962 and the

same calls for no interference. However, insofar as penalty

under Section 112(ii) is concerned, we find no evidence

showing    that     the   said   officer     dealt   with,       handled,

transported, concealed, possessed, or otherwise abetted

diversion of imported gold bars liable to confiscation under

Section 111 of the Customs Act. Invocation of Section 112(ii)

against him is therefore not legally sustainable.



(H) Departmental Appeal against Shri N.S.D. Avinash

Appraiser (Appeal No. C/40333/2024):

90.    We shall now examine the Department's grievance

insofar as non-imposition of penalty under Section 114AA of

the   Customs      Act,   1962   upon      Shri   N.S.D.   Avinash is

concerned. The materials on record establish that Shri

Avinash, though not rostered as Jewellery Appraiser on the

relevant   date,     undertook    examination        of    the     export

consignments, applied official endorsement and facilitated

export clearance despite apparent discrepancy between the

declared description of goods and the physical nature of the

articles presented for export.
                               54



91.   The evidence discussed hereinbefore demonstrates

that the export goods declared as "22 CT plain gold

jewellery" were in fact gold-coated copper/brass bangles

with very low gold purity. The discrepancy was not technical

or microscopic in nature but was sufficiently apparent to

attract immediate suspicion during examination. The nature

of discrepancy between the declared description and the

physical goods presented for examination was such that

endorsement and clearance could not reasonably have

occurred without conscious acceptance of materially false

declarations used in the customs process. Despite this, Shri

Avinash proceeded to facilitate export clearance by using

official endorsements in the customs process. The conscious

deviation from roster protocol coupled with authentication of

export examination materially contributed to the use of false

declarations and documents in customs proceedings. The

cumulative circumstances therefore sufficiently establish the

ingredients necessary for invocation of Section 114AA of the

Customs Act, 1962.



92.   Accordingly, apart from penalty under Section 114(iii),

we hold that penalty under Section 114AA of the Customs

Act, 1962 is also legally sustainable against Shri N.S.D.

Avinash. A penalty of Rs 20,00,000/_ is imposed on Shri

N.S.D. Avinash Appraiser under Section 114AA of Customs
                                  55



Act 1962. Consequently, the Departmental appeal against

Shri N.S.D. Avinash is partly allowed to the above extent.



(I) Departmental Appeal against SHRI P. Thulasi Ram,

Superintendent (Appeal No. C/40334/2024):

93.    We have carefully considered the submissions of the

Department as well as the defence taken by Shri P. Thulasi

Ram Superintendent in light of the findings recorded in the

Order-in-Original. The adjudicating authority itself has noted

that the actual examination of the impugned consignments

was carried out by Shri N.S.D. Avinash, Appraiser, and not

by Shri Thulasi Ram, though the latter's name/seal appeared

in the system records. It is also on record that due to heavy

workload and administrative constraints in the export shed,

Shri Thulasi Ram had permitted use of his brass seal by a

fellow officer who was also functioning as a jewellery

appraiser. The Order-in-Original, while discussing the role of

various noticees, does not bring out any independent or

corroborative evidence to establish that Shri Thulasi Ram

had physically examined the goods or had any role in

certifying   the   nature   of   the   consignment.   Thus,   the

foundational fact emerging from the record is that the

alleged lapse is not one of active involvement, but at best

one of procedural irregularity arising in the course of official

functioning by allowing the use of his official seal and signing
                                 56



the documents for a fellow officer in good faith being

rostered officer.



94.    The Departmental Appeal seeks to attribute abetment

to Shri Thulasi Ram on the ground that he signed documents

without examination. However, this contention does not

withstand legal scrutiny. The very evidence relied upon by

the Department, including statements of the Customs Broker

and the Appraiser, indicates that the examination and

processing of the consignment, including XRF testing and

grant of Let Export Order, were handled by Mr. Nerella

Samueal Deepak Avinash, Appraiser. In such a situation, the

primary responsibility for verification of goods rests with the

officer who actually undertook examination and clearance.

The mere fact that Shri Thulasi Ram's credentials were used,

cannot by itself establish knowledge of misdeclaration or

conscious facilitation of fraud. The Order-in-Original also

records that there is no evidence of collusion, no evidence of

any pecuniary benefit, and no material indicating any nexus

between Shri Thulasi Ram and the exporter or other co-

noticees. In the absence of these essential elements, the

statutory requirement of mens rea for invoking penalty

under Section 114(iii) is clearly not satisfied.
                                  57



95.   In view of the above, we find that the attempt of the

Department to elevate a procedural lapse into an act of

abetment is legally unsustainable. The facts on record, as

also appreciated in the Order-in-Original, only indicate that

Shri Thulasi Ram, faced with administrative exigencies,

permitted use of his seal in good faith without any

knowledge of the fraudulent export. There is no evidence of

conscious    involvement,    intentional   omission,    or    active

facilitation on his part so as to render him liable to penalty

under the Customs Act. It is well settled that negligence or

error in discharge of official duties, without accompanying

mens rea, cannot attract quasi-criminal liability. Accordingly,

we hold that Shri P. Thulasi Ram is eligible to be fully

absolved of penal proceedings under the Customs Act, 1962.



96. In view of the foregoing findings, we hold that the

exoneration of Shri P. Thulasi Ram, Superintendent of

Customs, in the impugned Order-in-Original is legally proper

and sustainable, inasmuch as the material available on

record does not establish any conscious involvement, mens

rea, collusion, or active facilitation on his part in the

fraudulent   export   of    mis-declared   jewellery.   The    acts

attributed to him, even if accepted in entirety, are in the

nature of procedural or administrative lapses arising in the

course of discharge of official duties and do not satisfy the
                                      58



essential statutory ingredients necessary for imposition of

penalty under Sections 114(iii) or 112(ii) of the Customs Act,

1962. We therefore find no infirmity in the conclusion

reached by the adjudicating authority in declining to impose

penalties    upon      Shri    P.    Thulasi   Ram.      Consequently,

Departmental        Appeal     No.   C/40334/2024      filed   by     the

Revenue against Shri P. Thulasi Ram is liable to be rejected

and accordingly stands dismissed.



(J) Penalties on Goldsmiths / Job Workers (Departmental

Appeal No. C/40331/2024)

97.   We    shall    now      examine     Departmental    Appeal     No.

C/40331/2024 whereby the Revenue has challenged the

decision    of   the   adjudicating       authority   dropping      penal

proceedings against Shri Zillur Rehman Mondal and Shri

Mainuddin Rehman Mondal. The impugned Order-in-Original

records that both the said noticees were engaged as

goldsmiths/job workers in relation to manufacture of gold-

plated imitation jewellery and that the Department alleged

their involvement in the larger fraudulent export scheme

concerning export of fake jewellery in the guise of 22-carat

gold jewellery. The adjudicating authority, however, after

analysing the evidentiary material available on record, came

to the conclusion that the role attributable to the said

noticees was confined to labour-oriented manufacturing

activity undertaken on job-work basis and that no material
                                59



existed establishing their conscious participation in diversion

of duty-free gold or fraudulent export of misdeclared

jewellery. Consequently, the adjudicating authority declined

to impose penalties upon them under the provisions of the

Customs Act, 1962.



98.   The Department in its Appeal has contended in the

present appeal that the adjudicating authority failed to

appreciate that the said goldsmiths actively participated in

manufacture of fake jewellery which ultimately formed part

of the export consignments and therefore ought to have

been visited with penalties under Section 117 of the Customs

Act, 1962. According to the Revenue, the very fact that the

goldsmiths     manufactured   gold-plated   imitation   jewellery

subsequently exported in place of genuine gold jewellery is

sufficient to establish conscious involvement in the offending

transaction.



99.   We are unable to accept the above contention in the

broad manner canvassed by the Department. The evidence

on record establishes that Shri Zillur Rehman Mondal and

Shri Mainuddin Rehman Mondal functioned only as job

workers carrying out labour-oriented activities such as

melting, moulding, soldering, polishing and preparation of

jewellery items under the instructions of Shri Ashok Jain
                                       60



using locally arranged material. The materials available on

record do not establish that they were importers, exporters,

financiers,       beneficiaries,     or     persons        exercising    any

operational control over procurement of duty-free gold, filing

of     shipping    bills,   preparation      of    export      declarations,

valuation, purity declaration, customs clearance formalities,

or movement of export consignments through Customs. Nor

is there evidence to show that they had any interaction with

Customs authorities or participated in export documentation.



100.     The distinction between participation in manufacturing

activity and conscious involvement in customs fraud assumes

considerable       significance      in    the    present      case.    Mere

manufacture        of    imitation    jewellery,      by     itself,   cannot

automatically lead to the inference that the goldsmiths were

aware of diversion of imported duty-free gold or of the

subsequent fraudulent export of such imitation jewellery

under the guise of genuine gold jewellery. The evidentiary

record does not disclose any pecuniary benefit linked to

export incentives, any financial flow-back, any recovery of

diverted imported gold from them, or any material showing

that they knowingly participated in the export fraud. The

Department has also not produced any evidence establishing

that    the   said      noticees     were    aware     that     the     goods
                                   61



manufactured by them would ultimately be exported by mis-

declaring them as genuine 22-carat gold jewellery.



101.   It is well settled that penal liability under Sections 117

of the Customs Act, 1962, being quasi-criminal in nature,

necessarily    requires    existence   of     conscious    knowledge,

intentional involvement, collusion, or active abetment. Mere

labour-oriented participation in a manufacturing process,

absent evidence of mens rea or conscious facilitation of

customs fraud, cannot by itself justify imposition of penalties

under the Customs Act. The adjudicating authority has

therefore     correctly   distinguished      between   the    principal

conspirators who orchestrated the export fraud and the job

workers who merely carried out manufacturing activities

without evidence of conscious participation in the larger

scheme.



102.   In the above factual and legal background, we find no

infirmity in the findings recorded in the impugned Order-in-

Original insofar as Shri Zillur Rehman Mondal and Shri

Mainuddin Rehman Mondal are concerned. The material

available     on    record    does     not     establish     conscious

involvement, collusion, mens rea, or active abetment on

their part so as to attract penal liability under Section 117 of

the Customs Act, 1962. Consequently, the decision of the
                                         62



adjudicating authority dropping penalties against the said

noticees      is     upheld      and     Departmental      Appeal     No.

C/40331/2024 is liable to be rejected.



(K)    HDFC        Bank   Ltd.   -     Penalties   Correctly   Dropped?

(Departmental Appeal C/40323/2024)

103.   The position of HDFC Bank Ltd. stands on an entirely

distinct footing. As already discussed, while deciding Issue

No. (iii), the liability of the Bank arose only within the

framework of Notification No.57/2000-Cus, the Foreign Trade

Policy, Handbook of Procedures, Circular No.27/2016-Cus

and the bond obligations executed by it as a nominated

agency importer. The records clearly establish that upon

detection of non-fulfillment of export obligation and diversion

of duty-free gold by M/s Shree Balaji Jewellers, HDFC Bank

discharged the entire customs duty together with applicable

interest even prior to issuance of the Show Cause Notice.

The    adjudicating       authority     specifically   appropriated   the

amounts so paid and further recorded absence of collusion,

wilful suppression, conscious misstatement or intentional

involvement on the part of HDFC Bank in the fraudulent

export transactions undertaken by the exporter.



104.   The Show Cause Notice had proposed penalties upon

HDFC Bank under Sections 112, 114(iii) and 114A of the

Customs Act, 1962 principally on the ground that the duty-
                                   63



free gold imported by the Bank ultimately stood diverted into

the domestic market through fraudulent exports of fake

jewellery. The Departmental Appeal specifically challenges

the findings of the adjudicating authority insofar as penalty

under Section 114A came to be dropped and the case was

held to fall under Section 28(1) and not under Section 28(4)

of the Customs Act. However, we find no statutory basis,

factual foundation, or evidentiary material to attribute mens

rea, abetment, conscious omission, collusion, or knowing

facilitation to HDFC Bank. Penal provisions under Sections

112,   114    and    114A    necessarily    require    conscious

involvement, intentional facilitation, wilful suppression, or

knowing participation in the offending acts. None of these

essential ingredients stand established against the Bank.



105.   The   Department     has    contended   that   being   the

importer     and    nominated      agency   under     Notification

No.57/2000-Cus, HDFC Bank remained absolutely liable for

all consequences arising from export of fake jewellery and

diversion of duty-free gold. We are unable to accept the said

contention in the broad manner canvassed by the Revenue.

While a nominated agency may remain answerable for

discharge of customs duty flowing from the exemption

notification and the executed bond obligations, the Customs

Act does not create automatic penal or vicarious liability
                                  64



upon a nominated agency for every subsequent fraudulent

act independently committed by exporters, job workers,

intermediaries, or examining personnel unless knowledge,

collusion, wilful suppression, or conscious failure of statutory

obligations is established against the nominated agency

itself. To hold otherwise would effectively convert a regulated

intermediary functioning under statutory supervision into an

insurer against all downstream criminal acts, a consequence

neither contemplated under Notification No.57/2000-Cus nor

supported by any express statutory provision.



106.   It is also significant that the adjudicating authority

specifically   recorded   that   none   of   the   persons   whose

statements were recorded during investigation implicated

any official of HDFC Bank in the fraudulent export activity

and further held that there existed no evidence establishing

collusion between the Bank and the exporter in commission

of the fraud. The adjudicating authority therefore rightly

concluded that the fraud had been perpetrated by M/s Shree

Balaji Jewellers without the knowledge of HDFC Bank and

consequently held that the demand, if any, would fall under

Section 28(1) and not under Section 28(4) of the Customs

Act, 1962. Once the substantive customs duty liability

together with applicable interest already stood discharged

prior to issuance of the Show Cause Notice itself, the
                                    65



foundational     jurisdictional    requirements       necessary    for

invoking Section 114A also remained wholly absent in view

of the provisions of Section 28(2) of Customs Act . It is also

significant that Section 28(2) of the Customs Act, 1962, as

applicable     during   the     relevant    period,    contemplated

conclusion of proceedings where the person chargeable with

duty voluntarily pays the customs duty together with

applicable interest prior to issuance of the Show Cause

Notice. In the present case, HDFC Bank discharged the entire

customs duty liability along with applicable interest through

the statutory bond mechanism even before issuance of the

SCN and the said payments were accepted and appropriated

by the Department. Once the adjudicating authority itself

recorded     absence    of    collusion,   wilful   suppression,   or

conscious involvement on the part of HDFC Bank and further

held that the case would fall under Section 28(1) and not

Section 28(4), the foundational requirement for sustaining

penalty under Section 114A also ceased to survive



107.   We also find considerable force in the reliance placed

upon the decision of the Coordinate Bench of this Tribunal in

HDFC Bank Ltd. v. Commissioner of Customs (Adjudication),

Delhi Zone, 2025 (10) TMI 825 (CESTAT-New Delhi),

wherein it was held that a nominated agency cannot be

penalised for fraudulent acts independently committed by
                               66



exporters in the absence of evidence establishing knowledge,

connivance, or conscious involvement of the importer. The

factual matrix in the present case stands materially similar.

The Bank had no role in manufacture of jewellery, export

processing, or diversion of gold and no evidence of collusion

or wilful breach of statutory obligation has been brought on

record. Accordingly, we hold that no penalty is imposable

upon HDFC Bank Ltd. under Sections 112, 114 or 114AA of

the Customs Act, 1962 and the Departmental appeal seeking

imposition of penalty upon the Bank is rejected.



Conclusion on Issue No.(iv) Penalties

108.   We also find that the adjudicating authority has

correctly distinguished between principal participants in the

fraudulent scheme and those against whom the evidence

merely establishes procedural lapse, labour-oriented activity,

or absence of conscious involvement. Accordingly, the

exoneration/dropping of penalties in respect of Shri P.

Thulasi Ram, Shri Zillur Rehman Mondal, Shri Mainuddin

Rehman Mondal and HDFC Bank Ltd. is found to be legally

proper and supported by the evidentiary record, there being

no material establishing the requisite mens rea, conscious

abetment, collusion, wilful suppression, or direct nexus

necessary for invocation of penal provisions under Sections

112, 114, 114A ,114AA or 117 of the Customs Act, 1962.
                                      67



Consequently,        the      respective       Departmental      appeals

challenging     such       exoneration    or   seeking   imposition    of

additional penalties against the aforesaid noticees stand

rejected.



109.     In   view    of    the   foregoing     discussion     and   upon

comprehensive consideration of the respective roles, degree

of     involvement,        evidentiary    materials,     and    statutory

requirements governing penal liability under the Customs

Act, 1962, we hold that the penalties imposed upon the

principal noticees directly connected with orchestration,

facilitation, and execution of the fraudulent export of fake

jewellery are legally sustainable and warrant confirmation.

The     evidence     on     record   clearly    establishes    conscious

involvement, active facilitation, deliberate misdeclaration,

diversion of duty-free gold, knowing use of false export

documentation, and intentional circumvention of statutory

safeguards on the part of M/s Shree Balaji Jewellers, Shri

Sunil Sharma, Shri Narendra Sharma, Shri Ashok Jain, M/s

BSM Logistics, Shri A. Mariappan, Shri T. Sankara Kumar and

Shri N.S.D. Avinash to the extent discussed hereinabove.

Accordingly, the penalties imposed upon the aforesaid

noticees under the respective provisions of the Customs Act,

1962 call for no interference except to the limited extent

specifically modified hereinabove insofar as non-applicability
                                  68



of penalty under Section 112(ii) against Shri N.S.D. Avinash

and non-applicability of penalty under Section 112(ii) against

Shri Narendra Sharma and Shri Ashok Jain are concerned.

Further, for the reasons separately recorded hereinabove,

penalty under Section 114AA against Shri Narendra Sharma

and Shri N.S.D. Avinash stands upheld. Consequently, the

respective   noticee   appeals        challenging   the   confirmed

penalties stand dismissed except to the limited extent

indicated hereinabove, and the connected Departmental

appeals stand disposed of in terms of the findings recorded

hereinabove.



(v).   Whether   Revenue    Appeals        on   non-imposition   of

redemption fine on the Importer i.e., HDFC Bank merit

acceptance C/40323/2024 : -

110.   We have carefully examined whether redemption fine

under Section 125 of the Customs Act, 1962 can be

sustained in respect of goods which are admittedly not

available for physical confiscation, having already been

cleared and utilised. We find merit in the appellants'

contention that redemption fine is not legally leviable in such

circumstances. Section 125 contemplates an option to

redeem confiscated goods in lieu of confiscation. The

statutory precondition for exercise of such option is the

physical availability of goods which can either be confiscated

or released on payment of fine. Where confiscation itself is
                                69



incapable of execution due to non-availability of goods, the

legal foundation for offering redemption necessarily fails.



111.   The Department has placed reliance on the decisions

in Weston Components Ltd. v. Commissioner of Customs

(Supreme Court), Visteon Automotive Systems India Ltd. v.

CESTAT (Madras High Court) to contend that, even though

the goods are not physically available, confiscation and

consequential proceedings are sustainable.



112.   The learned counsel for the appellants has relied upon

the decisions in Commissioner of Customs (Import), Mumbai

v. Finesse Creation Inc. [2009 (248) E.L.T. 122 (Bom)] as

affirmed by the Hon'ble Supreme Court [2010 (255) E.L.T.

A120 (S.C.)], and Union of India v. Raj Grow Impex LLP

[2021 (377) E.L.T. 145 (S.C.)], to contend that confiscation

is not sustainable where the goods are not physically

available.



113.   In the present case, we find that HDFC Bank Ltd.

stands on a fundamentally different footing. It is not the user

of the gold, not the manufacturer, not the exporter, and not

the beneficiary of the diversion. The Bank functioned as a

nominated agency operating under a statutory framework,

releasing gold to exporters against margin money and
                                 70



documentary      safeguards.    Crucially,   the    Adjudicating

Authority has recorded a categorical finding that there is no

evidence of collusion, wilful misstatement, or suppression

attributable to HDFC Bank especially where the importer is

demonstrably not complicit.



114.   Further, applying the binding ratio of the Coordinate

Bench in M/s. HDFC Bank Limited v. Commissioner of

Customs (Adjudication), Delhi Zone, 2025 (10) TMI 825

(CESTAT-New Delhi), we hold that redemption fine under

Section 125 of the Customs Act is wholly inapplicable to

HDFC Bank Ltd., as the Bank neither had physical custody

nor control over the export goods, nor any culpable role in

the fraudulent export by the jeweller. Redemption fine being

purely consequential to confiscation, and confiscation itself

being unsustainable against the Bank in the absence of

knowledge, mens rea, or dominion over the goods, the

Revenue's attempt to impose redemption fine amounts to

penalising a non-offending nominated agency for third-party

criminality.   Accordingly,   the    Revenue's   appeal   seeking

imposition of redemption fine on HDFC Bank Ltd. is rejected

in toto.



115.   In view of the above, we hold that while the goods

may be held liable to confiscation under Section 111(o) for
                               71



violation of Notification No. 57/2000-Cus., no redemption

fine under Section 125 can be imposed in respect of past

clearances where the goods are admittedly not available for

confiscation. The reliance placed by the Department on the

above case laws is therefore misplaced, and the Adjudicating

Authority's decision not to impose redemption fine calls for

affirmation, the impugned order to that extent is sustainable

and is so, upheld.



CONCLUSION

116.   At the same time, while deciding Issue Nos. (iii) and

(iv), we have drawn a clear distinction between the liability

arising under Notification No.57/2000-Cus and the bond

obligations executed by HDFC Bank Ltd. on the one hand and

the fraud-based allegations raised by the Department on the

other. The records clearly establish that HDFC Bank Ltd.,

functioning as the nominated agency importer, discharged

the entire customs duty together with applicable interest

prior to issuance of the Show Cause Notice and the

adjudicating authority itself recorded absence of collusion,

conscious involvement, or wilful suppression on the part of

the Bank in the fraudulent export transactions undertaken by

M/s Shree Balaji Jewellers. We have therefore upheld the

findings of the adjudicating authority insofar as HDFC Bank
                                         72



Ltd. is concerned and found no justification to interfere with

the dropping of further proceedings against the Bank.



117.   With regard to penalties, we have undertaken a role-

specific analysis of the conduct attributable to each noticee

and have confirmed penalties only where the evidence

establishes    conscious          involvement,        active        facilitation,

deliberate procedural deviation, intentional misdeclaration,

or knowing use of false documentation satisfying the

statutory requirements of the Customs Act, 1962. The

materials     on         record     clearly        establish         deliberate

misdeclaration, fraudulent intent, diversion of duty-free gold,

and active facilitation on the part of the principal exporter

entities and key operational participants connected with the

offending transactions.



118.   The     evidence         further       establishes      that     certain

intermediaries, including the Customs Broker M/s BSM

Logistics    and   its    key     personnel,       consciously       facilitated

circumvention of prescribed safeguards by coordinating

examination of export consignments outside the roster

mechanism and thereby enabled export of mis-declared

goods. In customs jurisprudence, abetment is not confined to

physical    handling      of    goods        and   extends     to    conscious

facilitation or intentional omission enabling commission of
                                 73



the offending act. The plea of absence of mens rea cannot

therefore be accepted where the cumulative conduct and

surrounding circumstances themselves establish conscious

facilitation.



119.    Insofar as departmental officers are concerned, we

find that the case against Shri N.S.D. Avinash, Appraiser, is

supported by material establishing active involvement in

examination and clearance of the impugned consignments

and consequently the penalty imposed upon him under

Section 114(iii) stands affirmed. We have also partly allowed

the connected Departmental Appeal and imposed penalty

under Section 114AA upon Shri N.S.D. Avinash to the extent

recorded hereinabove. However, insofar as penalty under

Section 112(ii) is concerned, we have found no evidence

establishing his involvement on the import side or any

dealing with imported duty-free gold liable to confiscation

under    Section   111   of   the    Customs   Act,   1962   and

consequently the penalty under Section 112(ii) against Shri

N.S.D. Avinash stands set aside. Similarly, the evidence on

record establishes that Shri Narendra Sharma played a

significant operational and coordinating role in the fraudulent

export scheme and consciously facilitated use of false export

documentation. Accordingly, while the penalty imposed upon

him under Section 114(iii) stands affirmed, we have also
                                      74



upheld imposition of penalty under Section 114AA against

Shri Narendra Sharma to the extent recorded hereinabove.

In the case of Shri P. Thulasi Ram, the evidentiary record

does not establish conscious involvement, collusion, or

intentional     facilitation   and    therefore       the   adjudicating

authority was justified in declining to impose penalties upon

him. Likewise, in the case of the goldsmiths/job workers and

HDFC Bank Ltd., the evidence falls short of establishing the

statutory     threshold    necessary      for   imposition       of   penal

consequences under the Customs Act, 1962.



120.   We have also remained conscious of the settled

principle that penal provisions under fiscal statutes, being

quasi-criminal in nature, require strict construction and

cannot be invoked merely on the basis of suspicion,

institutional     association,       or    retrospective         inference

unsupported by legally sustainable evidence. The conclusions

recorded      herein   therefore     represent    a    careful    balance

between enforcement of fiscal discipline and protection

against unwarranted penalisation.



121.   Taken as a whole, the present case reveals a carefully

orchestrated attempt to misuse a beneficial export promotion

scheme intended for genuine exports, resulting in loss to the

exchequer and erosion of regulatory trust. Such conduct
                                 75



warrants firm action under the Customs Act, 1962 both to

neutralise the economic advantage derived through misuse

of the scheme and to deter recurrence of similar fraudulent

practices. At the same time, entities against whom the

evidence    does   not   establish   conscious   involvement    or

facilitation cannot be subjected to penal consequences

merely because they formed part of the broader commercial

or institutional framework within which the fraud occurred.



122.    In conclusion, we hold that the impugned Order-in-

Original substantially merits affirmation subject only to the

limited modifications and clarifications specifically recorded

hereinabove. The findings recorded in the present Final

Order    reflect   a   comprehensive    appreciation    of   facts,

evidence,    statutory    provisions,   exemption      notification

conditions, FTP obligations, CBEC Circular framework, and

binding judicial precedents including the Coordinate Bench

decision in M/s HDFC Bank Ltd. v. Commissioner of Customs

(Adjudication), Delhi Zone. All judgments relied upon by the

respective parties have been considered in the context of the

issues framed and have either been applied or distinguished

depending upon their applicability to the factual matrix of the

present case.
                                      76



ORDER

123. In view of the foregoing discussion, findings and conclusions recorded hereinabove, the following order is passed: -

i. The confiscation of the exported goods weighing 10,172.53 grams covered under Shipping Bill No.7870940 dated 31.01.2022 under Sections 113(i) and 113(ja) of the Customs Act, 1962, together with the option of redemption on payment of fine as ordered in the impugned Order-in-Original, is affirmed. ii. The finding regarding diversion of 8,475.78 grams of duty-free gold imported under Notification No.57/2000- Cus rendering the same liable to confiscation under Section 111(o) of the Customs Act, 1962 is upheld. Inasmuch as the said gold is not physically available for confiscation, the decision of the adjudicating authority refraining from imposing redemption fine in respect thereof is also upheld.
iii. The penalties imposed upon Shri Sunil Sharma proprietor of M/s Shree Balaji Jewellers under Sections 114(iii), 114AA and 112(ii) of the Customs Act, 1962 are upheld and consequently Noticee Appeal No. C/40543/2024 stands dismissed.
77
iv. The penalty imposed upon Shri Narendra Sharma under Section 114(iii) of the Customs Act, 1962 is upheld. Further, the Departmental Appeal seeking imposition of penalty under Section 114AA is allowed and penalty of Rs.20,00,000/- (Rupees Twenty Lakhs only) is imposed upon Shri Narendra Sharma under Section 114AA of the Customs Act, 1962. However, the Departmental Appeal seeking imposition of penalty under Section 112(ii) against Shri Narendra Sharma is rejected. Consequently, Noticee Appeal No. C/40544/2024 stands dismissed and the connected Departmental Appeal stands partly allowed to the above extent. v. The penalty imposed upon Shri Ashok Jain under Section 114(iii) of the Customs Act, 1962 is upheld. However, the Departmental Appeal seeking imposition of penalty under Section 112(ii) against Shri Ashok Jain is rejected. Consequently, Noticee Appeal No. C/40545/2024 stands dismissed and the connected Departmental Appeal stands rejected.
vi. The penalties imposed upon M/s BSM Logistics, Shri A. Mariappan and Shri T. Sankara Kumar under Section 114(iii) of the Customs Act, 1962 are upheld and 78 consequently Noticee Appeal Nos. C/40546/2024, C/40547/2024 and C/40548/2024 stand dismissed. vii. The penalty imposed upon Shri N.S.D. Avinash under Section 114(iii) of the Customs Act, 1962 is upheld. However, the penalty imposed upon him under Section 112(ii) is set aside and consequently his Noticee Appeal stands partly allowed to the said limited extent. Further, the Departmental Appeal seeking imposition of penalty under Section 114AA against Shri N.S.D. Avinash is allowed and penalty of Rs.20,00,000/- (Rupees Twenty Lakhs only) is imposed upon Shri N.S.D. Avinash under Section 114AA of the Customs Act, 1962.
viii. The dropping of penalties against Shri P. Thulasi Ram is upheld and consequently Departmental Appeal No. C/40334/2024 stands rejected.
ix. The dropping of penalties against Shri Zillur Rehman Mondal and Shri Mainuddin Rehman Mondal is upheld and consequently Departmental Appeal No. C/40331/2024 stands rejected.
79
x. The findings of the adjudicating authority holding that the customs duty liability together with applicable interest stood discharged prior to issuance of the Show Cause Notice in terms of Notification No.57/2000-Cus, Circular No.27/2016-Cus, FTP/HBP provisions and the executed bond obligations is also upheld. Consequently, the dropping of proceedings relating to further duty demand, interest, redemption fine, and penalties against HDFC Bank Ltd. is affirmed and Departmental Appeal No. C/40323/2024 stands rejected in toto. xi. The impugned Order-in-Original No.32/2024-AIR dated 03.02.2024 passed by the Principal Commissioner of Customs, Air Cargo, Chennai is accordingly upheld subject to the limited modifications and clarifications recorded hereinabove.

124. All appeals and connected Departmental appeals stand disposed of in the above terms.

(Order pronounced in open court on 08.05.2026) Sd/- Sd/-

(VASA SESHAGIRI RAO)                                                (P. DINESHA)
 MEMBER (TECHNICAL)                                                MEMBER (JUDICIAL)
MK