( 1 ) THE question involved in this application is the date from which a notification issued in a Gazette comes into effect.

( 2 ) THE basic fact of the matter, which is admitted, is as follows: 602 and 900 pieces of spherical roller bearing over 60 mm diameter of Russian origin were shipped from Dubai on August 20, 1996. A shipping manifest was filed by the owner of the shipping, Marine Containers Service India Pvt. Ltd. , after the same was handed over to them by shipping company Natvar Parikh Industries Limited. The two bills bearing entry Nos. 0711 and 0732 were filed by the clearing agent on September 10, 1996 and presented before the concerned appraiser for assessment on September 11, 1996. On September 11, 1996 the vessel Tiger Creek in which the aforementioned assignment was being transshipped obtained permission at about 16. 25 hrs. At 5. 30 P. M. the Finance Bill No. 2 of 1996 was presented wherein a proposal was made to raise customs duty on ball or roller bearing from 25 per cent + 2 per cent C. V. 15 per cent to 10 per cent + Rs. 80/- per kg. and C. V. 15 per cent. On September 12, 1996 the berthing of the said vessel took place. The respondents assessed the customs d

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