(a) a contract for the supply of 1231.508 M/Tonnes of Refined Industrial Coconut Oil was concluded between the appellant and M/s. Patel Holdings, Singapore on 11.1.1982, who had duly exported them to India by the vessel "Aurora Glory" through three Bills. of Lading for 155.7933 M/Tons, 6.15.1337 M/Tons and 460.581, M/Tons respectively;

(b) The appellant filed, on 2.11.1982, three separate Bills of Entry Nos. 263, 264 and 265 in respect of the aforesaid shipments. The ship arrived on 4.11.1982;

(c) A notice dated 3.2.1983 was issued to the Appellant requiring them to show cause against confiscation of the goods under S.111(d) and a levy of penalty Under Section 112 of the Customs Act, 1962. This notice was adjudicated by the Collector who by his aforesaid order held that the import licences produced by the appellant did not cover the imports and directed confiscation of the coconut oil in question, subject to redemption on payment of a fine of Rs. 85,00,000/-, for import thereof in violati