J U D G M E N T

In these cases, the challenge raised by the petitioners is with regard to the demand notices issued against them (Ext.P6 in W.P.(C) No. 38971 of 2024 and Ext.P5 in W.P.(C) No. 38995 of 2024), demanding the amount of IGST short-paid, when the petitioners carried out certain imports. The said demand letters were issued based on Ext.P1 orders issued in both cases under Sec.28 of the Customs Act, 1962 .

2. The facts which led to the filing of these writ petitions are as follows:- In WP(C) 38971/2024, the petitioner is a partnership firm and conducting business under the name and style ‘Al Kabeer Exporters’. The firm is registered under the Kerala Goods and Services Tax Act, 2017, Central Goods and Services Tax Act and the Integrated Goods and Services Tax Act 2017. As part of the business of importing dates and other food products, the petitioner imported different grades of semi- dried dates, as per Bill of Entry No.7617965 dated 08.05.2020 through Cochin Sea Port. In the Bill of Entry furnished by the petitioner, the goods were classified as semi-dried dates and included under the CTH08041020. However, in the said bill of entry, the petitioner availed exemption from I