IN THE HIGH COURT OF GUJARAT AT AHMEDABAD R/TAX APPEAL NO. 927 of 2007 With R/TAX APPEAL NO. 928 of 2007 ===============================================================

KASHYAP A PATEL Versus THE COMMISSIONER OF CUSTOMS.

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Appearance:

KUNTAL A PARIKH(7757) for the Appellant(s) No. 1 MR CB GUPTA(1685) for the Opponent(s) No. 1 ===============================================================

CORAM:HONOURABLE MR. JUSTICE BHARGAV D. KARIA and HONOURABLE MR. JUSTICE PRANAV TRIVEDI Date : 15/10/2025 COMMON ORAL ORDER (PER : HONOURABLE MR. JUSTICE BHARGAV D. KARIA)

1. Heard learned advocate Mr.Kuntal A. Parikh for the appellants and learned advocate Mr.C.B.Gupta for the respondent.

2. These Appeals are filed under Section 130 of the Customs Act, 1962 against the Judgment and Order dated 11.05.2006 passed by the Customs, Excise and Service Tax Appellate Tribunal, West Zonal Bench, Mumbai (for short ‘the CESTAT’) in Appeal No.C/532/531/665 of

1999.

3. By order dated 21.08.2007 the Appeals are admitted on the following two substantial questions of law :

“(a) Whether in the facts and circumstances of the case it was open to the Tribunal to h