JUDGMENT

C. Hari Shankar, J.

REVIEW PET. 117/2020 (filed by respondent) & CM APPL. 20797/2022

1. This order disposes of Review Petition 117/2020, preferred by the respondent, seeking review of the judgment dated 1st June 2020, whereby we had disposed of CUSAA 229/2019.

2. The circumstances in which this Review Petition came to be filed have a bearing on its fate; ergo, it would be appropriate to chart the course of proceedings, till its filing, albeit briefly.

3. Gold, imported into India by the respondent, was seized by the Directorate of Revenue Intelligence (DRI), in part from the workshop/factory premises of the respondent and in part from the Airport, after the gold had crossed the Customs barrier. The respondent disputes the legitimacy of the seizure, contending that the gold had been earlier exported by the respondent and was being re-imported into India within a year of export, and was entitled, therefore, to complete duty exemption under S. No. 5 of Notification 45/2017-Cus dated 30th June 2017, as further clarified by CBIC Circulars Nos 21/2019-Cus dated 24th July 2019 and 108/27/2019-GST dated 18th July 2019. A Show Cause Notice came to be issued by the DRI to the respo