( 1 ) BY this writ petition the petitioner challenged the show cause notice No. S. 15-25/25-5ib dated 9. 5. 1985. The said show cause notice was issued under Section 124 of the Customs Act, 1962 (For short the said Act hereafter ). The said show cause notice read thus: notice UNDER SECTION 124 OF THE CUSTOMS ACT, 1962 subject:- Import of 246. 140 M/t in 108 bundles of low carbon mild steel CRCA sheets declared as defective Ex-s. s. Vanil, rot No. 217/85 dated 2. 5. 1985 line No. 61 and 196. 980 M/t low carbon mild steel CRCA sheets declared as defective ex-Vanil, rot No. 217/85, line No. 62 importers M/s. S. A. International, P-3, New C. I. T. Road, Calcutta - 73, Shippers M/s. ETS A-P Landowski Samis, Paris, Port of shipment Antwerp - undervaluation and unauthorised import - regarding. 1. M/s. C Bose and Sons, Customs House Agents filed two bills of entry on behalf of M/s. S. A. International, P-3, New I. I. T. Road, Calcutta 73 for clearance of two consignments of low carbon mild steel defective CRCA sheets (as declared) shipped from Antwerp ex-s. s. Vanila rot No. 217/85, line No. 61 and 62 covering quantities 246. 14 M/t and 196. 98 M/t clearances of the said con