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"28. We find that the Respondent No.2, namely, DGFT, through
Para 8.3.6 of the HOP has incorporated by reference the provisions
of Duty Drawback Rules mutatis mutandis to the FTP and HOP. We
find substance in the contention of Mr Ghosh that the HOP is
nothing but an administrative guideline as would appear from a
combined reading of Para 2.4 of the FTP and Section 6 of the FTDR
Act. We have already pointed out that Section 3 of the FTDR Act
grants power to the Respondent No.1 to make provisions relating to
imports and exports and the Respondent No.1 under Section 5 of
the FTDR Act can formulate and announce the foreign trade policy.
It further appears from Section 6(3) of the FTDR Act that of the
powers conferred upon the Respondent No.1 under the FTDR Act,
except those provided in Sections 3,5,15,16 and 19, all others can
be delegated to the Respondent No.2 by order published in the
Official Gazette. We find that the Respondent No.2 through Para
8.3.6 of the HOP has sought to incorporate the provisions of Duty
Drawback Rules to deemed exports mutatis mutandis which is not
permissible in view of the fact that no power has been granted to
the DGFT under the FTDR Act to legislate either directly or by way
of incorporation by reference. It is now a settled law that the
separation of power between the legislature and executive forms
part of the basic structure of the Constitution of India and any
attempts by the executives to legislate without appropriate
authority under the law would amount to violation of the basic
structure of the Constitution of India. The power to legislate is
incorporated under Article 246 of the Constitution of India and
such power has been conferred on the Parliament and the State
Legislature. Moreover, the power to frame Duty Draw Back Rules
under the FTDR Act can be legislated by the Central Government
only in exercise of power conferred under Section 19 in the manner
C/SCA/1849/2019 JUDGMENT
prescribed under the FTDR Act and the same cannot be delegated to
the Respondent no. 2 as expressly prohibited by Section 6(3) of the
above Act.