COMMISSIONER OF CUSTOMS (IMPORT) vs BEETAL TELETECH LIMITED

* IN THE HIGH COURT OF DELHI AT NEW DELHI % Judgment delivered on: 13.01.2025 CUSAA 30/2024 COMMISSIONER OF CUSTOMS (IMPORT) .....Appellant Through: Mr Akshay Amritanshu, Senior Standing Counsel with Mr Samyak Jain, Ms Drishti Safar and Ms Pragya Upadhyay, Advocates. versus BEETAL TELETECH LIMITED .....Respondent Through: Mr Srinivas Kotni and Mr Shyam Kishor Maury, Advocates. CORAM HON’BLE THE ACTING CHIEF JUSTICE HON’BLE MS. JUSTICE SWARANA KANTA SHARMA JUDGMENT SWARANA KANTA SHARMA, J. INTRODUCTION 1. The Revenue has preferred the present appeal under Section 130A of the Customs Act, 1962 [hereafter „the Act‟] read with Section 174 of the Central Goods and Services Tax Act, 2017, impugning the order dated 30.10.2023 [hereafter „the impugned order‟] passed by the learned Customs, Excise, and Service Tax Appellate Tribunal, Principal Bench, New Delhi [hereafter „the learned CESTAT‟], by way of which the appeal filed by the Revenue (Customs Appeal No. 51875 of 2021) was dismissed. 2. The principal controversy in the present case was captured by this Court in order dated 12.09.2023 (passed in CUSAA 38/2023) while framing the question of law, which is set out below: Whether the word