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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
C/SCA/12808/2018 JUDGMENT
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 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.