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11. The term 'importer' is defined under Rule 2(c) of the Foreign Trade (Regulation) Rules, 1993 which reads as under:-

W.P.(C) 1788/2011 Page 6 of 10
"(c) "importer" or "exporter" means a person who imports or exports goods and holds a valid Importer-exporter Code Number granted under section 7"

12. By the impugned order dated 07.09.2006, a penalty of `2,50,000/- was imposed on Balaji on the basis that it had imported the offending goods. This is apparent from the contents of the said order, the relevant extracts of which are quoted below:-