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     Failed to establish                           No foreign markings
     FOREIGN ORIGIN                                found on the gold
                                                   Appraisement report
                                                   confirms Gold's weight &
                                                   value, does not indicate
                                                   foreign origin
                                                   Statement of Noticee 5 &
                                                   6 suggest purity of gold
                                                   does not match foreign
                                                   origin
Penalty of Rs. 5,00,000     Authority held         No mens rea established.
imposed under Section       appellant knowingly    Appellant lawfully
112(b).                     dealt with smuggled    procured gold with
                            goods.                 invoices & registers.
                                                   Burden of proof under
                                                   Section 123 lies on
                                                   Department. Failure to
                                                   prove foreign origin
                                                   negates penalty.
Allegation that documents OIO/OIA rejected         Appellant consistently
(stock registers, bills,    documentary evidence produced authentic
melting reports) are        without verification.  documents. Authorities
afterthought/fabricated.                           ignored them instead of
                                                   verifying. Documents
                                                   prove lawful stock.
                                                   Rejection without
                                                   examination is arbitrary.
Appellant IV implicated for                        His role for managerial,
instructing his employees                          did not directly partake in
to retrieve                                        any physical act of
gold from Delhi. OIO                               smuggling.
suggests his action                                His business practices
contributed to smuggling                           such as purchasing gold
                                                   without formal receipts (a
                                                   method used to avoid
                                                   excessive tax \duty)
                                                   though legally debatable,
                                                   are     standard       in     the
                                                   industry and should not
                                                   automatically imply illicit
                                                   activity.
                                                   His business records and
                                                   stock registers that
                                                   corroborate the legal
                                                   procurement of gold.
                                                   His appeal also highlights
                                                   the retraction filed on 07.
                                                   02. 2024, clarifying that
                                                   carlier statements (made
                                                    Customs Appeal Nos.70576-70579 of 2025


                                                       under pressure) were not
                                                       reflective of actual
                                                       practices.
As per the OIO & SCN,                                  Orders- He was merely a
                                                       salaried employee, acting
Appellant      I     recorded
                                                       on direct orders from the
statement implicated him                               senior management, had
                                                       no independent decision
in the smuggling process.
                                                       making authority
                                                       regarding procurement or
                                                       transport.
                                                       Noticee 3 contends that
                                                       his initial statement was
                                                       given under coercion and
                                                       has since been retracted.
                                                       This retraction is crucial in
                                                       his appeal as it
                                                       undermines the basis of
                                                       the evidence used against
                                                       him.
                                                       No additional
                                                       documentary evidence
                                                       links him personally to
                                                       any wrongful conduct
OIO Includes Appellant III                             He functioned as a driver,
                                                       followed his employer's
statement as evidence of
                                                       instructions.
his   involvement     in   the
alleged            smuggling
activity.
SCN Allegation                                         An amount of
                                                       Rs.1,22,00,000/- cash
                                                       was given to Noticee 3
                                                       (Aksh Jha) by Sh. Umesh
                                                       Jha (Noticee 1)

A delayed retraction, without immediate complaint to judicial authorities appears to be an afterthought aimed at escaping liability. Furthermore, these statements were not Customs Appeal Nos.70576-70579 of 2025 made in isolation; they were corroborated by substantial evidence:

i. The recovery of gold meticulously concealed in a specially constructed cavity within the vehicle. ii. The initial denial by Appellants 1 and 3 upon interception, followed by admission only after notices under Sections 102 & 106 were served.

Customs Appeal Nos.70576-70579 of 2025 5.7 The story of purchasing jewellery, melting it into bullion (on 10.09.2023), and immediately sending it to Delhi (11.09.2023) for remaking jewellery appears highly contrived and presented post-facto. The documents (invoices, melting report, stock entries) submitted months after the seizure, which were never mentioned or produced during the initial search or investigation despite opportunities, lack credibility and are reasonably considered an afterthought designed to create a defence. The Adjudicating Authority's finding that this is a cooked- up story is well-reasoned.

5.15 Based on the detailed analysis of the evidence on record, the statements recorded under Section 108 of the Act, the circumstances of the seizure, the corroborative evidence including CDR analysis and testing slips, and the admissions made, I find that the appellants were actively involved in a well-planned operation to smuggle foreign- origin gold procured illicitly in Delhi. The grounds raised in the appeals are found to be without merit and appear to be attempts to obfuscate the facts established during the investigation and adjudication proceedings. The narrative presented regarding legitimate procurement and transport for jewellery making is an unconvincing afterthought, contradicted by the appellants' own initial admissions and the circumstances of the case. The Adjudicating Authority has passed a well-reasoned order based on the evidence. 4.3 The first question that needs to be answered is whether the gold recovered from the personal possession of Appellant-I and from the activities carried in KIA Seltos is of smuggled gold or not?