JUDGMENT :

Ranjan Gogoi, J.

1. Order on the admission of this appeal has been kept pending to enable the Court to ascertain the true sweep and purport of the appellate power of this Court under Section 130E(b) of the Customs Act, 1962 (as amended). The language of the above provision of the Act having indicated a very broad and expansive appellate jurisdiction, the precise contours thereof were felt necessary to be determined and the admissibility of the present appeal tested on the aforesaid basis.

2. It may be worthwhile at the very outset to delve into the history of the taxation regime under the Act to notice the changes that had occurred from time to time.

3. Against the assessment of customs duty made by different assessing authorities under the Act, viz., Deputy Collector of Customs/Collector of Customs, initially, an executive appellate remedy before the Collector of Customs and before the Central Board of Customs Excise and Customs, depending on the authority which has passed the initial order of assessment, was provided. There was a power of suo motu revision with the Board as well as a revisional jurisdiction to be exercised on an application by an aggrieved person. The Cent