JUDGMENT

This appeal is directed against the judgment and order of the Delhi High Court dated 22-8-1980 allowing the respondents writ petition made under Article 226 of the Constitution and quashing the show cause notices issued to the respondent under Sections 28 and 124 of the Customs Act, 1962.

2. The respondent-company imported 13,500 MT of RBD Palm Oil under Open General Licence from Singapore between November 1978 and March 1979. The foreign suppliers supplied the goods in stainless steel containers, and same were allowed to be cleared under Section 47 of the Customs Act. Subsequently, a show cause notice under Section 28 of the Customs Act was issued by the Assistant Collector, Bombay to the respondent-company on the ground that the -stainless steel drums were subject to levy of custom duty. The respondent-Company submitted reply to the notice. Another show cause notice was issued to the respondent Company on June 21, 1980 by the Collector, Bombay under Section 124 of the Customs Act calling upon them to explain why the stainless steel drums should not be confiscated as the import of stainless steel was prohibited. In its reply the respondent-Company asserted that it had not i