Heard the Counsel for the petitioner and the Advocate General on behalf of the respondents.

2. The factual background is as follows:-

The petitioner is a company incorporated under the Companies Act, 1956. It is a subsidiary of M/s. Flemingo International Limited, Dubai.

The petitioner has set up "Duty-free shops” at various International Airports in India. This was enabled by the Airports Authority of India (hereinafter called ‘AA’ for brevity) calling for lenders to construct, develop and operate such shops at several International Airports, including the Bangalore International Airport (hereinafter referred to as ‘BIA’ for brevity). The petitioner's parent company was a successful bidder. The AAI had awarded a licence in the year 2004 to establish and operate Duty-free shops at the arrival and departure terminals of the BIA. The petitioner is the recognised subsidiary in terms of the licence, authorised to operate the shops.

The petitioner has obtained a licence under Section 58(1) of the Customs Act, 1962, to operate as a private bonded warehouse for the storage of goods brought from abroad, to be sold to transit international passengers against approved foreign curren