SYED ARSHAD ALL J. This consolidated judgment shall dispose of the instant Custom Reference as well as connected Custom References, the detail whereof is provided in Annexure "A" of this judgment in view of commonality in facts albeit questions of law.
ESSENTIAL AND RELEVANT FACTS OF THE CASE.
2. Respondent is a registered construction company and possesses a license issued by Pakistan Engineering Council certifying its building and construction operations in Pakistan.
IMPORT POLICY ORDER, 2013 ("IPO, 2013")
3. The following two provisions of IPO, 2013 are relevant to the present controversy: "Para 4. Imports of Goods,-Imports of all goods is allowed from worldwide sources unless otherwise elsewhere specified to be banned, prohibited or restricted in this Order: Provided that the amendments brought in this Order from time to time shall not be applicable to such imports where Bill of Lading (B/L) or Letters of Credit (L/C) were issued or established prior to the issuance of amending Order.
Para 9 Import of used plant, machinery and equipment.
(ii) Import of Secondhand plant, Machinery and Equipment and Specialized Machinery by Construction, Mining and Petroleum Sector.
(5) Construction companies, mining, oil, gas and petroleum sector companies are also allowed to import specialized vehicle-mounted machinery and transport equipment such as mobile transit mixture, concrete pumps, crane lorries, concrete placing trucks, dumpers designed for off highway use, cement bulkers and prime movers 380 HP and above, etc, specified in Appendix-I. However, import of such items will be subject to certification by the competent authority of exporting country or a recognized pre-shipments inspection company listed at Appendix-H to the effect that the said machinery or transport equipment (a) is compliant with Euro-II emission standards
(b) is in good working condition and has a remaining productive life of five years. "
Underlining is for emphasis being relevant. > 06th October, 2015.
4. A contract was executed between the respondent MIS Jan Builders with MS Alkhair Mettle Trading FZC Office No.11G-19 Sharjah (UAE) for the import of crane mounted trucks (HS code 8705-1000), Prime Movers (HS8701-2040), Dumper Trucks (HS 8705-1090), Concrete Texture (HS 8705-4000), Rough Terrain Cranes (HS8705-1000) and other headings HS 8705-0000. "Goods" According to this agreement the shipment was to be made within two years or more after receipt of LC sight through any bank of Pakistan.
5. The aforesaid contract was followed by a proforma invoice by the Exporter dated 13' October 2015 reaffirming the said condition of contract. > 20th October, 2015.
6. The respondent's construction company applied to JS Bank Limited for the issuance of LC having a validity period of 24 months in favour of the foreign exporter. However, on 20.10.2015 the LC was issued by the Bank for a period of 12 months which was to expire on 19.10.2016. (For a total amount of US $ 3.20 Million)
IMPORT POLICY ORDER, 2016 7 The Federal Government while exercising its power under section 3 of Import & Export (Control Act, 1950) issued Import Policy Order of 2016 through SRO No.345 (i)/2016 dated 18.04.2016. The relevant para is reproduced as under: "9 (5) Import of used plant, machinery and equipment,---the import shall be as under. -- Construction companies, mining oil, gas and petroleum sector companies are also allowed to import specialized vehicle-mounted machinery and transport equipment such as mobile transit mixer, concrete pumps, crane lorries, concrete placing trucks, dumpers designed for off highway use, cement bulkers and prime movers '280' HP and above, etc, including those specified in Appendix-I. Import of said specialized machinery or transport equipment as mentioned above shall however, be subject to prior pre-shipment inspection in the exporting country from any of the Internationally recognized pre-shipments inspection companies listed at Appendix-H to the effect that the said machinery or transport vehicles are (a) Euro-II complaint (b) manufactured as such by Original Equipment Manufacturer (OEM) , and ( c) not older than five years,-and"
Underlining is for emphasis being relevant. > 17th October,10.2016
8. On 17.10.2016 upon the request of the respondent, the LC which was already issued in favour of the beneficiary on 20.10.2015 was further extended till 19.10.2017 on the same terms and conditions for total amount of US$3.20 Million.
RESTRICTIONS IMPOSED BY THE FEDERAL GOVERNMENT UNDER THE FOREIGN REGULATION ACT, 1947.
9. Chapter 13 para 9 (2) of Foreign Exchange Manual, 2016 lays down the following restrictions on the issuance of letter of credit.
"If the Import Policy does not lay down any instruction in this regard, they may open letters of credit for a period up to 12-months. However, in respect of machinery and mill-work which are required to be specifically manufactured and the period of manufacture is more than 12-months, the letter of credit may be opened for a period up to 24-months. The validity of a letter of credit may be extended by the Authorized Dealers for further periods not exceeding 12-months at a time on payment offee, ifso prescribed in the Import Policy, provided there has been no change in the Import Policy/Exchange Regulations in relation to the importability of the goods, the country of origin/shipment and the method of payment/and if approached within its validity. An expired letter of credit may also be similarly revalidated subject to the same conditions."
10. The Goods arrived in Pakistan during a period from 04.05.2017 onward were seized by the respondents as evident from the Seizure Report dated 04.05.2017, 10.05.2017 etc.
11. On 03.07.2017 Mr. Qurban Ali Khan, The Collector Customs while exercising power under section 168 (2) of the Customs Act, 1969 had allowed the extension in time for issuance of show cause notices and completion of investigation in contravention/seizure cases framed by Staff of the Customs Dry port Peshawar against MS Jan Builders Peshawar. > 18th Jul t12017.
12. Show cause notice was issued to the respondent wherein the precise allegations are that the respondent had imported the Goods in violation of the IPO, 2016 and the instructions contained in Foreign Exchange Manual which are reproduced as following: "That according to the IPO, 2016 the construction company could not import the imported goods whose age is more than 05-years as prohibited under para 9 sub clause 5 of IPO, 2016 and the LC was extended during the subsistence of the said IPO, 2016 which is violation of Chapter 13 para 9
(ii) of Foreign Exchange Manual issued by the State Bank of Pakistan."
OPINION OF THE STATE BANK OF PAKISTAN DATED 30.05.2017.
"The Assessing Officer has also solicited opinion of the State Bank of Pakistan regarding the revalidation of letter of credit. The State Bank of Pakistan had opined through letter dated 30.05.2017 "that the LC was extended by the bank in violation of existing Foreign Exchange Regulation and the provision of Import Policy Order, 2016, thus Pakistan Customs may proceed accordingly in the matter." > OPINION OF THE SEIZING OFFICER THROUGH ORDER DATED 08.11.2017.
"Considering the overall circumstances of the case, I am favorably inclined to hold that the importer namely M/S Jan Builders Construction Company, its clearing agent M/S Ittehad Customs Agency and M/S JS Bank have violated the aforesaid provisions of law. Nothing substantially was brought on record to disprove the allegations leveled against them. 1, therefore, order for outright confiscation of the seized old & used dumps trucks (08 in number) in favour of the State in terms of the aforesaid provisions of law.
As M/S fans Builders, M/S Ittehad Customs Clearing Agency and M/S JS Bank have violated the provisions of Paragraph 9 (ii) (5) of Import Policy Order, 2016 read with Section 3 (1) of the Imports and Exports (Control) Act, 1950, Chapter 13 Para 9(ii) of Foreign Exchange Manual, 2016 issued by SBP, Section 16 & 32 (1)(c ) of the Customs Act, 1969 which is punishable under section 156 (1)(9)(1)
(ii),(14) & (90)of the Act ibid and Section 3 (3) of the Imports and Exports (Control) Act, 1950 read with Foreign Exchange Manual, 2016 therefore, a penalty equivalent to three times of value of the goods is imposed upon each of them in terms of the aforesaid provisions of law." > OPINION OF THE CUSTOMS APPELLATE TRIBUNAL, PESHAWAR BENCH (" THE TRIBUNAL")
13. Since, in the present matter, there were conflicting views between the two members, therefore the matter was referred to the Worthy Chairman of the Tribunal. The Worthy Chairman concurred with the Opinion of Member Legal. The Worthy Tribunal has framed the following issues for their determination: -
(i) What is the legal effect of revalidation of the Letter of Credit (L.C)?
(ii) Whether the right of importers were protected under proviso to clause (4) of Import Policy Order, 2013?
(iii) Whether the provision of 168 (2) and 179 (3) of the Act are complied with by the lower forum?
14. It is the majority opinion of the Tribunal that since the contract between the Foreign Exporters and the respondent importer was executed on 06.10.2015, the letter of credit was opened on 20.10.2015 for a period of two years for an amount of US$3.2-million and the subsequent amendment of LC has not changed the amount of LC, therefore, in terms of para 4 of IPO, 2013, the restrictions imposed through IPO, 2016 are not applicable. The Tribunal has also held that the extension in time under section 168 of the Act was granted by an incompetent authority, therefore, the matter was decided in favour of the respondent.
15. The department has challenged the findings of judgment dated 17.11.2022 of the Tribunal whereby numbers of questions of law have been raised. > ARGUMENTS OF THE LEARNED COUNSEL FOR THE DEPARTMENT.
16. Mr. Abdur Rauf Rohaila, learned senior advocate, appearing on behalf of the petitioner's department while opening his arguments and reiterating the facts of the case has argued that admittedly the original agreement was executed between the Foreign Exporter and the Respondent prior to IPO, 2016 followed by establishment of letter of credit which had a validity till 19.10.2016. The IPO, 2016 was promulgated on 18.04.2016 and the letter of credit was extended on 17.10.2016 when admittedly there was a ban on the import of second-hand/old machinery as its age was more than five years. He has also referred to Chapter-13 of Foreign Exchange Manual Regulations and has maintained that the LC could only be validated when the import does not offend the import policy of the Federal Government. Since, in this case, the Import Policy Order, 2016 had banned/restricted the import of used vehicle having an age of more than five years, therefore, the LC was illegally validated by the bank. He next argued that para 4 of IPO, 2013 would not be applicable to the present case because according to proviso to para 4 of IPO, 2013 when only amendment was made in IPO, 2013, it will not affect the establishment of the LCs, however, in the present case the restrictions were imposed by IPO, 2016 superseding the IPO 2013. In support of his arguments the learned counsel for the petitioner has relied upon the judgment of the apex Court passed in Civil Petition No.1239 of 2014 dated 15.07.2014. > ARGUMENTS OF LEARNED COUNSEL FOR THE RESPONDENT.
17. Mr. Aamir Bilal, learned advocate, representing the Respondent has argued that in the present case admittedly the agreement was executed between the Respondent and Importer on 06.10.2015 relating to the import of old machinery which was permissible under IPO, 2013. The letter of credit was issued on 20.10.2015 for a total amount of US$ 3.2-millions. Since the original agreement was for a period of two years, therefore, upon the request of the Respondent only the expiry date of the LC was extended for a further period of one year, and during the said period the Respondents were able to import the goods. Therefore, the restrictions of IPO, 2016 cannot be applied to the case of the Respondents in view of proviso to para 4 of IPO, 2013 as neither any new LC was established, nor any restrictions of the State Bank of Pakistan of Federal Government violated.
We have heard and considered the respective contentions of the learned counsels for the parties and perused the record.
19. The precise question for consideration of this court is "Whether in the circumstances of the present case; when a binding agreement for import of Goods was executed between the Foreign Exporter and the Respondent on 08.10.2015 against which the issuing bank (JS Bank) issued irrevocable letter of credit on 20.10.2015 valid up to 19.10.2016 for total amount of US$-3.20 Million which was amended only to the extent of extension in time on 17.10.2016 during the period when IPO, 2016 was in field, prohibiting the import of used vehicles older than five years, the said amendment in the LC on 17.10.2016 would disentitle the Respondent of their right to import the vehicle which was permissible under IPO, 2013".
20. It is admitted that the condition of import of vehicles prior to IPO, 2016 was that the said vehicle should have a remaining productive life of five years which condition was amended through IPO, 2016 allowing the import of the said vehicles except those which were not older than five years. The essential attributes of the letter of credit established by the Respondent through JS Bank were against the import of vehicles for a total quantity equal to an amount of US$-3.20 Million importable within two years, however, this letter of credit was for period of one year despite the fact that the Respondent-importer had requested the bank for the issuance of letter of credit for 24- months in line with the terms & condition of contract which provides that the vehicles would be delivered to the Respondent within two years. The learned Tribunal in this regard has maintained that probably it was a clerical error at the time of issuance of letter of credit relating to the expiry date.
21. We have perused para 9(2) Chapter 13 of Foreign Exchange Manual 2016 reproduced in para 9 of this judgment. The Manual in clear terms authorizes the bank to allow establishment of L/C for a period of 24 months relating to the import of machinery and mill work which are required to be specifically manufactured in a period beyond 12 months and the said period of 24 months can still be extended for further period of 12 months. Therefore, we do not tend to agree with the arguments of Mr. Rohaila that the impugned import of the Respondent in any manner offends the restrictions imposed by Foreign Exchange Manual.
22. Proviso to Para 4 of IPO, 2013 also in very unambiguous words mentions that any amendment made in IPO, 2013 shall not be applicable to such import where the bill of lading (B/L) or letter of credit (L/C) was issued or established prior to the issuance of amending order.
23. In the present case at the time of execution of the agreement for import of Goods IPO 2013 was in field followed by the proforma invoice and establishment of letter of credit however, at the time of amendment in the letter of credit only to the extent of expiry period, IPO, 2016 was notified restricting the import of the vehicle as stated above. The question arises whether the amendment in the L/C through letter dated 17.10.2016 would amount to the establishment of fresh letter of credit or the same is only extension in time. The bare perusal of the amendment in L/C dated 17.10.2016 would show that the parties are the same, initial contract is the same, total amount/value of import (US$-3.20 Million) was the same, and till 17.10.2016, not a single vehicle was imported into Pakistan thereby exhausting the letter of credit. Therefore, it cannot be assumed that amendment in letter of credit dated 17.10.2016 was a process relating to an import during the subsistence of IPO 2016 rather it was a chain in the same series of transactions initiated under IPO 2013 and the transaction was completed with the issuance of LC on 20.10.2015.
24. There are certain established principles of interpretation of fiscal instruments. It is a well settled rule of interpretation that an executive authority cannot in exercise of the rule making power or the power to amend vary or rescind the earlier order, take away the right vested in citizen by law. The apex Court in the case of Aziz ud Din Industries Limited[1] has observed that it is well settled that no statute shall be construed so as to have retrospective operation unless its language is such as plainly to require such construction.
25. In the case of Al-Samrez Enterprises[2] the apex Court was dealing with the matter of withdrawing of an exemption on import of certain goods. In the said case the appellant had executed a binding contractor with the foreign exporter and subsequent to the said agreement material steps were taken in form of establishing irrevocable letter of credit, however, later at the time of payment of duty the said notification granting exemption was withdrawn. In such scenario the apex court has held, "we are therefore, clearly of the opinion that i f a binding contract was concluded between the appellants and the foreign exporter or steps were taken by the appellants created a vested right to the then existing notification granting exemption, the same could not be taken away and destroyed in modification of the earlier one, on the ground that under section 21 of the General Clauses Act, the government could exercise the power of modification." The apex court in order to bolster the observation has referred to the Maxwell's Interpretation of Statutes, 1962 at page 206 wherein it is observed that every statute, which takes away or impairs vested rights acquired under existing laws, or creates a new obligation, or imposes a new duty, or attaches a new disability in respect of transactions or considerations already past, must be presumed, out of respect to the legislature, to be intended not to have a retrospective operation.
26. The general principle with regard to the interpretation of statutes laid down in the well-known case of the Colonial Sugar Refining Company Limited v. Irving 1901 A C 369 is that "if the matter in question be a matter of procedure only", the provisions - would be retrospective. "On the other hand, if it be more than a matter of procedure, if it touches a right in existence at the passing of the Act", then "in accordance with multiline authorities, the legislation will not operate retrospectively, unless the Legislature had either "by express enactment or by necessary intendment" given the legislation retroactive effect.
27. The learned counsel for the petitioner has relied upon the judgment of the apex Court in the case of Haj i Abdur Raziq Khan (2014 SCMR 1821). In the said case the issue before the apex Court was interpretation of para 4 of IPO, 2013. The condition of import under the Import Policy Order of 2009 was amended through Import Policy Order of 2013 and the effect was that Crane lorries or sprinkle classified under PTC Head 8705 were importable except those which were not older than five years. Prior to this amendment there were no age restrictions relating to the import of crane lorries or sprinkle classified. The Importer in the case requested the Meezan Bank to open a sight LC in sum of US$200,000 for import of sprinkle lorries against 110% cash margin. Pursuant to the said Meezan Bank had established ten LCs of different dates. Two LCs were issued prior to the change in the Import Policy through IPO, 2013 whereas the other LCs were issued established after IPO, 2013.
Keeping the said scenario, the apex Court in the concluding paragraph had held that: - "Meezan Bank Ltd, through its letter dated 31.05.2013 addressed to the Deputy Collector, Model Customs Colkctorate, Hyderabad has tried to explain the nature of dealing between the petitioner and bank but has erroneously mentioned that the LC dated 23.01.2013 in the sum of US$200,000/- will be amended from time to time in terms of the amount as per proforma invoice dated 11.01.2013 and the agreement dated 21.01.2013 and that LC will remain that of 23.01.2013 with its expiry on 21.01.2014. If we read this letter closely, it will only mean that there will be a separate LC issued or established in terms of the amount for which it is required to be issued or established as per instructions of the petitioner and that this will keep on going until proforma invoice and agreement between the parties is exhausted for which terminal date is fixed as 21.01.2014. The amendment in the LC is confined to the terms and conditions of that very LC that is of 23.01.
2013and the new LCs issued or established cannot be considered to be an amendment in the LC dated 23.01.2013. Nothing more than this can be subscribed from said letter of Meezan Bank We may also note that the transaction under LC dated 23.01.2013 as specified in its terms and conditions was completed and exhausted and this LC did not remain alive to incorporate amendments to include further transactions in it. The mandate of law does not, in our view, provide for such situation nor any law; in this respect was shown to us by the learned ASC of the petitioner."
28. Thus, in Abdul Raziq' case supra the apex Court has given protection to the LCs which were opened /established prior to change in the import policy. It was only the transaction pursuant to the establishment of fresh LCs when IPO 2013 was in field was held illegal.
29. The outcome of above discussion would be that if we read Proviso to Para 4 of IPO, 2013, the judgment passed by the apex Court in Abdul Raziq case supra, and the restrictions imposed by the State Bank of Pakistan through Chapter 13 Para 9(ii) of Foreign Exchange Manual, 2016, the effect would be that if an importer has executed a binding agreement with the Foreign Exporter and the exports were to be made in a particular period of time, the binding agreement is followed by establishment of letter of credit, however, if for certain reasons only the expiry of the letter of credit is altered the said import would be considered under the IPO, 2013 notwithstanding the fact that at the time of amendment in the LC only to the extent of extension in time the IPO, 2016 was in field prohibiting the said import of Goods. These findings are bolstered by the century old rule of interpretation that the Court must lean against giving a statute retrospective operation on the presumption that the legislature does not intend what is unjust. It is chiefly where the enactment would prejudicially affect vested rights, or the legality of past transaction, or impair existing contacts, that the rule in question prevails. If two interpretations are equally possible, the one that saves vested rights would be adopted in the interest of justice, specially where we are dealing with taxes statute.3 It is equally settled law that the interpretation of fiscal statute has to be made strictly and any doubts arising from the interpretation of a fiscal provision must be resolved in favour of the taxpayer.' Needless to mention that IPO 2016 is the statutory policy of the Federal Government exercising the delegated authority under section 3 of Import & Export (Control Act 1950).
30. In view of what has been stated above, we hold that the conclusion drawn by the majority judgment of the Tribunal is in accordance with law and do16es not call for interference. Resultantly, this Custom Reference as well as connected Customs References are answered in negative.
Copy17 of this judgment be sent to the learned Tribunal in terms of Section 196 (5) of the Act.
Annexure "A"
S.NO.CUSTOM REFERENCE NUMBERTITLE 1.Custom Reference No.19-P/2023. Collector of Customs (Appraisement) MCC, Peshawar/ Vs Jan Builders, Peshawar.
2.Custom Reference No.20-P/2123 Collector of Customs r (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
3.Custom Reference No.21-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
4.Custom Reference No.22-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
5.Custom Reference No.23-P12023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
6.Custom Reference No.24-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
7.Custom Reference No.25-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
8.Custom Reference No.26-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
9.Custom Reference No.27-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
10.Custom Reference No.28-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
11.Custom Reference No.29-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
12.Custom Reference No.30-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
13.Custom Reference No.31-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
14.Custom Reference No.32-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
15.Custom Reference No.33-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
16.Custom Reference No.34-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
17.Custom Reference No.35-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
18.Custom Reference No.36-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
19.Custom Reference No.37-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
20. Custom Reference No.38-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs JS Bank Shaheen Complex Branch, Karachi.
21.Custom Reference No.39-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
22. Custom Reference No.40-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
23. Custom Reference No.41-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
24. Custom Reference No.42-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
25. Custom Reference No.43-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Jan Builders, Peshawar.
26. Custom Reference No.44-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
27. Custom Reference No.45-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
28. Custom Reference No.46-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
29. Custom Reference No.47-P/2023.Collector of Customs (Appraisement) MCC, PeshawaL Vs Ittehad Customs Clearing Agency Peshawar Cantt.
30. Custom Reference No.48-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs lttehad Customs Clearing Agency Peshawar Cantt.
31. Custom Reference No.49-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
32. Custom Reference No.50-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs lttehad Customs Clearing Agency Peshawar Cantt.
33. Custom Reference No.51-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
34. Custom Reference No.52-P12023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
35. Custom Reference No.53-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Mency Peshawar Cantt.
36. Custom Reference No.54-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
37. Custom Reference No.55-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs lttehad Customs Clearing Agency Peshawar Cantt.
38. Custom Reference No.56-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs lttehad Customs Clearing Agency Peshawar Cantt.
39. Custom Reference No.57-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
40. Custom Reference No.58-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
41. Custom Reference No.59-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
42. Custom Reference No.60-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
43. Custom Reference No.61-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
44. Custom Reference No.62-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
45. Custom Reference No.63-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs lttehad Customs Clearing Agency Peshawar Cantt
46. Custom Reference No.64-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
47. Custom Reference No.65-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs Ittehad Customs Clearing Agency Peshawar Cantt.
48. Custom Reference No.66-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
49. Custom Reference No.67-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
50. Custom Reference No.68-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
51. Custom Reference No.69-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
52. Custom Reference No.70-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
53. Custom Reference No.71-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
54. Custom Reference No.72-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
55. Custom Reference No.73-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
56. Custom Reference No.74-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
57. Custom Reference No.75-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S IS Bank Shaheen Complex Branch, Karachi.
58. Custom Reference No.76-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
59. Custom Reference No.77-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
60. Custom Reference No.78-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
61. Custom Reference No.79-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
62. Custom Reference No.80-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
63. Custom Reference No.81-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
64. Custom Reference No.82-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
65. Custom Reference No.83-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S IS Bank Shaheen Complex Branch, Karachi.
66. Custom Reference No.84-P12023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
67. Custom Reference No.85-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
68. Custom Reference No.86-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs MIS JS Bank Shaheen Complex Branch, Karachi.
69. Custom Reference No.87-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs MIS JS Bank Shaheen Complex Branch, Karachi.
70. Custom Reference No.88-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
71. Custom Reference No.89-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs M/S JS Bank Shaheen Complex Branch, Karachi.
72. Custom Reference No.90-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs MIS JS Bank Shaheen Complex Branch, Karachi.
73. Custom Reference No.91-P/2023.Collector of Customs (Appraisement) MCC, Peshawar Vs MIS JS Bank Shaheen Complex Branch, Karachi.
[1]Collector of Central Excise and Land Customs Vs Aziz ud Din Industries Limited (PLD 1970 SC 439).
2. AI-Samrez Enterprise Vs The Federation of Pakistan (1986 SCMR 1917) revisions by the competent authorities. Therefore, it is advisable to consult the official sources or legal professionals for the most up-to-date and accurate information.