1. Since the issues raised in all the captioned appeals are identical, those were taken up for hearing analogously and are being disposed of by this common order.

2. There are in all 14 appeals before us. Eleven are at the instance of the Revenue and three are at the instance of the respective assessees. Some of the appeals arise from the judgment and order passed by the Delhi High Court wherein the Revenue is the appellant whereas the other appeals arise from the judgment and order passed by the Bombay High Court wherein the assessees are in appeal before us.

3. For the sake of inconvenience, we treat C.A. No.3489/2024 as the lead matter.

4. This appeal arises from the judgment and order passed by the High Court of Delhi, dated 04.09.2012, in the Writ Petition (Civil) No.2952/2012, by which the High Court allowed the Writ Petition, filed by the respondent herein, declaring that the effect of non - issuance of show - cause notice, under S.124 of the Customs Act, 1962 (for short, the Act, 1962'), within the stipulated period as prescribed under S.110(2) of the Act, 1962, would entitle the person, from whose possession goods are seized, for release of the same.

5. The facts giving rise to this appeal may be summarised as under:

6. The respondent herein questioned the legality and validity of the Seizure Panchnama dated 09.05.2012, drawn by the Directorate of Revenue Intelligence (DRI) before the High Court in connection with seizure of a car (Maserati). The respondent herein is engaged in the business of trading in imported brand new and domestically purchased second hand luxury cars. He purchased a brand new Maserati car on 07.12.2010. The Revenue, i.e., the DRI, in exercise of powers under S.110 of the Act, 1962, detained the car on the same day and handed it over to the appellant vide a panchnama. Thereafter, by order dated 24.10.2011, the Commissioner of Customs extended the period for issuance of show - cause notice by a further period of six months w.e.f. 25.10.2011, under S.110(2) of the Act, 1962. On 09.05.2012, the DRI, by panchnama cancelled the supurdarinama and took possession of the Maserati Car. In such circumstances, referred to above, the respondent went before the High Court by way of a Writ Petition seeking release of the car.

7. It was argued before the High Court on behalf of the respondent herein (original writ petitioner) that upon expiry of the period of one year from the date of seizure of the car, he was entitled to an unconditional release of the same.

8. On the other hand, while opposing the Writ Petition, it was argued on behalf of the DRI that since the car was provisionally released on 09.05.2012, under the provisions of S.110A of the Act, 1962, the period during which the provisional order of release was in operation would entitle the DRI to say that the period of six months had not expired in accordance with S.110 of the Act, 1962. The High Court looked into S.110 of the Act, 1962, which reads thus:
"110. Seizure of goods, documents and things. - (1) If the proper officer has reason to believe that any goods are liable to confiscation under this Act, he may seize such goods:
Provided that where it is not practicable to remove, transport, store or take physical possession of the seized goods for any reason, the proper officer may give custody of the seized goods to the owner of the goods or the beneficial owner or any person holding himself out to be the importer, or any other person from whose custody such goods have been seized, on execution of an undertaking by such person that he shall not remove, part with, or otherwise deal with the goods except with the previous permission of such officer:
Provided further that where it is not practicable to seize any such goods, the proper officer may serve an order on the owner of the goods or the beneficial owner or any person holding himself out to be importer, or any other person from whose custody such goods have been found, directing that such person sha