2026:BHC-OS:3534-DB IN THE HIGH COURT OF JUDICATURE AT BOMBAY TRUSHA TUSHAR ORDINARY ORIGINAL CIVIL JURISDICTION MOHITE Digitally signed by TRUSHA TUSHAR MOHITE Date: 2026.02.06 CUSTOMS APPEAL NO.2 OF 2025

16:53:51 +0530 Principal Commissioner of Customs (General) .. Appellant Versus A.B.Paul & Co. .. Respondent Mr. M.P.Sharma a/w Ms.Mamta Omle, Advocate for the Appellant.

Mr.Anil Balani a/w Ms.Priyasha Pawar, Advocate for Respondent.

CORAM: B. P. COLABAWALLA &

FIRDOSH P. POONIWALLA, JJ. DATE: FEBRUARY 4, 2026 P. C.

1. The above Appeal is filed by the Revenue challenging the Order dated 2^nd June 2023 passed by the Customs, Excise & Service Tax Appellate Tribunal, Mumbai (‘CESTAT’) in Appeal No.86451 of 2022. The Appeal before the CESTAT was filed by the Respondent Assessee herein. According to the Revenue, the impugned Order of the CESTAT gives rise to the following substantial questions of law:

“a. "Whether the Hon'ble Tribunal erred in not considering the fact that the timeline contained in Regulation 20 cannot be construed to be mandatory & is held to be directory & further ignoring the fact that it should be taken into consideration whether procedural lapses such as non-adherence to