Plain-English Explanation

Plain English Summary

Overview

Section 28AAA of the Customs Act, 1962, addresses situations where customs duties are sought to be evaded by misuse of instruments (like licenses, certificates, or duty credit scrips) obtained through collusion, wilful misstatement, or suppression of facts. It allows for the recovery of duties from the person who originally obtained the instrument improperly, even if someone else ultimately used it. This section acts as a safeguard against fraudulent availment of benefits under various schemes related to customs duties.

Who Does This Apply To?

This section primarily applies to:

  • Individuals or entities who obtain instruments (licenses, scrips, authorisations, etc.) through collusion, wilful misstatement, or suppression of facts, intending to utilize them under the Customs Act or related laws.
  • Importers utilizing instruments obtained under various schemes for duty exemptions or remissions.
  • Customs officers responsible for recovering evaded duties.

How It Works

Section 28AAA operates through the following steps:

  • Instrument Obtained Improperly: A person obtains an instrument (defined in Explanation 1 of the section) by means of collusion, wilful misstatement, or suppression of facts. This instrument could be issued under the Foreign Trade (Development and Regulation) Act, 1992, or any other law or scheme related to duty exemptions, rewards, or incentives.
  • Instrument Utilized by Another: The instrument obtained improperly is then utilized under the Customs Act by someone other than the person who obtained it. This could involve using the instrument to claim duty exemptions or reductions on imported goods.
  • Duty Recovery: The duty that was exempted or debited due to the utilization of the instrument is deemed never to have been exempted. The customs authorities can then recover this duty from the person who originally obtained the instrument improperly. Note that this action is without prejudice to any action under Section 28 against the importer (the person who actually used the instrument for customs clearance).
  • Notice and Opportunity: Before recovering the duty, the proper officer serves a show cause notice to the person who obtained the instrument, allowing them 30 days to explain why the amount should not be recovered. After considering their representation and giving them a hearing, the officer determines the final amount of duty and interest to be recovered.
  • Interest: In addition to the duty, the person is also liable to pay interest at the rate fixed by the Central Government under Section 28AA, calculated from the date of utilization of the instrument until the date of recovery.
  • Order and Payment: An order is passed specifying the amount of duty and interest to be recovered. The person must repay the amount within 30 days of receiving the order.
  • Recovery Mechanism: If the person fails to repay the amount within 30 days, it will be recovered as per the provisions of Section 142(1) of the Customs Act.

Important Conditions & Exceptions

  • Condition 1: The instrument must be utilized under the provisions of the Customs Act, rules, regulations, or notifications issued thereunder.
  • Condition 2: The provisions of this section apply to any utilization of instruments obtained improperly on or after the date the Finance Bill, 2012 received presidential assent, regardless of when the instrument was initially issued.
  • Exception: If an order determining the duty has already been passed under Section 28, no separate order to recover that duty will be passed under Section 28AAA. This prevents double recovery of the same duty.

Practical Example

Suppose "ABC Exporters" obtained an export license fraudulently by misrepresenting their export performance. This license entitled them to a duty credit scrip worth ₹50 lakhs. They sold this scrip to "XYZ Importers," who used it to import goods, thereby evading customs duties of ₹50 lakhs. Even though XYZ Importers used the scrip, under Section 28AAA, the Customs Department can recover the ₹50 lakhs duty from ABC Exporters, along with applicable interest, because they were the ones who obtained the license through fraudulent means. This is in addition to any potential action against XYZ Importers under Section 28 for incorrect availment of the duty exemption.

Key Amendments

No major amendments since enactment.

Section 28AAA. Recovery of duties in certain cases. -1
(1)Where an instrument issued to a person has been obtained by him by means of-1
(a)collusion; or1
(b)wilful misstatement; or1
(c)suppression of facts, for the purposes of this Act or the Foreign Trade (Development and Regulation) Act, 1992 (22 of 1992), or 1any other law, or any scheme of the Central Government, for the time being in force, by such person2 or his agent or employee and such instrument is utilised under the provisions of this Act or the rules 1or regulations3 made or notifications issued thereunder, by a person other than the person to whom the instrument was issued, the duty relatable to such utilisation of instrument shall be deemed never to have been exempted or debited and such duty shall be recovered from the person to whom the said instrument was issued:1
Provided that the action relating to recovery of duty under this section against the person to whom the instrument was issued shall be without prejudice to an action against the importer under section 28.1
Explanation 1 - For the purposes of this sub-section, "instrument" means any scrip or authorisation or licence or certificate or such other document, by whatever name called, issued under the Foreign Trade (Development and Regulation) Act, 1992 (22 of 1992), 1or duty credit issued under section 51B, with respect to4 a reward or incentive scheme or duty exemption scheme or duty remission scheme or such other scheme bestowing financial or fiscal benefits, which may be utilised under the provisions of this Act or the rules made or notifications issued thereunder.1
Explanation 2 - The provisions of this sub-section shall apply to any utilisation of instrument so obtained by the person referred to in this sub-section on or after the date on which the Finance Bill, 2012 receives the assent of the President, whether or not such instrument is issued to him prior to the date of the assent.1
(2)Where the duty becomes recoverable in accordance with the provisions of sub-section (1), the person from whom such duty is to be recovered, shall, in addition to such duty, be liable to pay interest at the rate fixed by the Central Government under section 28AA and the amount of such interest shall be calculated for the period beginning from the date of utilisation of the instrument till the date of recovery of such duty.1
(3)For the purposes of recovery under sub-section (2), the proper officer shall serve notice on the person to whom the instrument was issued requiring him to show cause, within a period of thirty days from the date of receipt of the notice, as to why the amount specified in the notice (excluding the interest) should not be recovered from him, and after giving that person an opportunity of being heard, and after considering the representation, if any, made by such person, determine the amount of duty or interest or both to be recovered from such person, not being in excess of the amount specified in the notice, and pass order to recover the amount of duty or interest or both and the person to whom the instrument was issued shall repay the amount so specified in the notice within a period of thirty days from the date of receipt of the said order, along with the interest due on such amount, whether or not the amount of interest is specified separately.1
(4)Where an order determining the duty has been passed under section 28, no order to recover that duty shall be passed under this section.1
(5) Where the person referred to in sub-section (3) fails to repay the amount within the period of thirty days specified therein, it shall be recovered in the manner laid down in sub-section (1) of section 142.1any other law, or any scheme of the Central Government, for the time being in force, by such person2 or his agent or employee and such instrument is utilised under the provisions of this Act or the rules or regulations3 made or notifications issued thereunder, by a person other than the person to whom the instrument was issued, the duty relatable to such utilisation of instrument shall be deemed never to have been exempted or debited and such duty shall be recovered from the person to whom the said instrument was issued:
Provided that the action relating to recovery of duty under this section against the person to whom the instrument was issued shall be without prejudice to an action against the importer under section 28.
Explanation 1 - For the purposes of this sub-section, "instrument" means any scrip or authorisation or licence or certificate or such other document, by whatever name called, issued under the Foreign Trade (Development and Regulation) Act, 1992 (22 of 1992), or duty credit issued under section 51B, with respect to4 a reward or incentive scheme or duty exemption scheme or duty remission scheme or such other scheme bestowing financial or fiscal benefits, which may be utilised under the provisions of this Act or the rules made or notifications issued thereunder.
Explanation 2 - The provisions of this sub-section shall apply to any utilisation of instrument so obtained by the person referred to in this sub-section on or after the date on which the Finance Bill, 2012 receives the assent of the President, whether or not such instrument is issued to him prior to the date of the assent.
(2)Where the duty becomes recoverable in accordance with the provisions of sub-section (1), the person from whom such duty is to be recovered, shall, in addition to such duty, be liable to pay interest at the rate fixed by the Central Government under section 28AA and the amount of such interest shall be calculated for the period beginning from the date of utilisation of the instrument till the date of recovery of such duty.
(3)For the purposes of recovery under sub-section (2), the proper officer shall serve notice on the person to whom the instrument was issued requiring him to show cause, within a period of thirty days from the date of receipt of the notice, as to why the amount specified in the notice (excluding the interest) should not be recovered from him, and after giving that person an opportunity of being heard, and after considering the representation, if any, made by such person, determine the amount of duty or interest or both to be recovered from such person, not being in excess of the amount specified in the notice, and pass order to recover the amount of duty or interest or both and the person to whom the instrument was issued shall repay the amount so specified in the notice within a period of thirty days from the date of receipt of the said order, along with the interest due on such amount, whether or not the amount of interest is specified separately.
(4)Where an order determining the duty has been passed under section 28, no order to recover that duty shall be passed under this section.
(5)Where the person referred to in sub-section (3) fails to repay the amount within the period of thirty days specified therein, it shall be recovered in the manner laid down in sub-section (1) of section 142.]

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Frequently Asked Questions

What is the purpose of Section 28AAA of the Customs Act, 1962?

Section 28AAA aims to recover customs duties when an 'instrument' (like a license or scrip) used for duty exemption or reduction has been obtained through collusion, wilful misstatement, or suppression of facts by the person to whom it was issued, and is subsequently used by another person. It ensures that the duty, which was initially exempted or debited due to the fraudulent instrument, is recovered from the original recipient of the instrument.

What constitutes an 'instrument' under Section 28AAA of the Customs Act, 1962?

As per Explanation 1 of Section 28AAA, an 'instrument' includes any scrip, authorization, license, certificate, or similar document issued under the Foreign Trade (Development and Regulation) Act, 1992, or duty credit issued under section 51B. It essentially encompasses any document that bestows financial or fiscal benefits, such as those related to reward, incentive, duty exemption, or duty remission schemes, that can be utilized under the Customs Act.

If duty is recoverable under Section 28AAA, what additional charges apply?

Besides the recoverable duty, the person from whom the duty is recovered is also liable to pay interest, as per Section 28AAA(2). The interest rate is determined by the Central Government under Section 28AA, and it's calculated from the date the instrument was utilized until the date the duty is recovered.

What is the procedure for recovery of duties under Section 28AAA of the Customs Act, 1962?

The proper officer must serve a show cause notice on the person to whom the instrument was issued, providing them 30 days to explain why the specified amount (excluding interest) should not be recovered, as per Section 28AAA(3). After considering their representation and providing a hearing, the officer determines the amount to be recovered and issues an order, specifying a 30-day repayment period, including interest.

Does Section 28AAA apply if a duty demand has already been determined under Section 28?

No, Section 28AAA(4) explicitly states that if an order determining the duty has already been passed under Section 28 (general provision for recovery of duty), no order to recover that duty can be passed under Section 28AAA. This prevents duplicate recovery actions for the same duty amount.

What happens if the person fails to repay the amount determined under Section 28AAA within the specified time?

According to Section 28AAA(5), if the person fails to repay the amount within 30 days as specified in the recovery order, the amount will be recovered in the manner laid down in Section 142(1) of the Customs Act, 1962. This refers to methods like attachment and sale of property to recover the dues.

When did Section 28AAA come into effect, and does it apply retrospectively?

Explanation 2 of Section 28AAA specifies that the provisions apply to any utilization of instruments obtained fraudulently on or after the date the Finance Bill, 2012 received presidential assent, regardless of whether the instrument was issued before or after that date. This means the section has retrospective applicability to the utilization of fraudulently obtained instruments.

Key Conditions & Requirements

ConditionDetails
Instrument obtained by collusion, misstatement, or suppression If an instrument (e.g., scrip, license) was obtained by collusion, wilful misstatement, or suppression of facts, and is utilized by another party, the duty is recoverable.
Recovery from instrument recipient, not the importer The duty is recovered from the person who originally obtained the instrument through illicit means, even if another person utilized the instrument.
Applicable from Finance Bill 2012 assent date This section applies to instrument utilizations occurring on or after the date the Finance Bill, 2012 received presidential assent, regardless of when the instrument was issued.
Interest payable on recovered duty In addition to the recoverable duty, interest at a rate fixed by the Central Government under section 28AA is payable from the date of utilization until the date of recovery.
Show cause notice and opportunity to be heard The proper officer must issue a show cause notice giving 30 days to respond and an opportunity to be heard before recovering the duty and interest.
Repayment period after order The person to whom the instrument was issued must repay the amount specified in the order, along with interest, within 30 days of receiving the order.
Section 28 action is preserved Action against the instrument holder does not preclude separate action under Section 28 against the importer.
No recovery order if duty determined under Section 28 If an order determining the duty has already been passed under section 28, no separate recovery order can be issued under this section.

Amendment History

1234Superscript numbers in the text mark amended passages — click them to jump here. Click "↑ view in text" to jump back.
1

Substituted by the Finance Act, 2012 (23 of 2012), section 122 (w.e.f. 28-5-2012)

2

Substituted (w.e.f. 27-3-2020) s.109 (a) of Finance Act 2020 (12 of 2020)

3

Inserted (w.e.f. 27-3-2020) s. 109 (b) of Finance Act 2020 (12 of 2020)

4

Substituted (w.e.f. 27-3-2020) s. 109 (c) of Finance Act 2020 (12 of 2020)

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