455/2017 Spl:Sales Tax Ref: A. Commissioner Inland Revenue (Applicant) V/S M/s. New Allied Electronics Industries (Pvt) Ltd. (Respondent)

Sindh High Court2021

Bench: Hon'ble Chief Justice Mr. Justice Muhammad Shafi Siddiqui(Author), Hon'ble Mr. Justice Agha Faisal

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455/2017 Spl:Sales Tax Ref: A. Commissioner Inland Revenue (Applicant) V/S M/s. New Allied Electronics Industries (Pvt) Ltd. (Respondent) Sindh High Court Bench: Hon'ble Chief Justice Mr. Justice Muhammad Shafi Siddiqui(Author), Hon'ble Mr. Justice Agha Faisal Order Date: 08-SEP-21 Under Customs Act, 1969, Section 79 onwards is a procedure which regulates the import through filing of Goods Declaration along with necessary documents including examination of imported goods and clearance thereof. Such mechanism was adopted and exhausted by the customs when goods declaration was dealt with. The purported allegation of misdeclaration was in fact within the domain and jurisdiction of Collectorate of Customs, which, in case of any controversy, could have retained the consignment/goods for further inquiry or chemical test and determine the duty provisionally till disposal of the inquiry or reassessment. This has not happened in the instant case as had it been a misdeclaration of the goods, the officers concerned may have taken cognizance and could have objected to the assessment in terms of Section 193 and 195 of Customs Act, 1969 read with Section 32 of the said Act. Sales Tax Act, 1990 does not deal with issue of misdeclaration as being dealt with by the customs officials under Customs Act, 1969. Therefore, unless a misdeclaration is established by the customs officials such recourse of recovery of short levy of sales tax could not have been triggered. The dispute of classification was never raised at customs level.
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