MARUTI SUZUKI INDIA LIMITED vs UNION OF INDIA & ORS.

IN THE HIGH COURT OF DELHI AT NEW DELHI Date of Decision: 12th March, 2025 W.P.(C) 6842/2021 and CM APPL. 34893/2022 CM APPL. 12343/2023 MARUTI SUZUKI INDIA LIMITED ..... Petitioner Through: Mr. Yogendra Aldak, Mr. Karan Sachdev, Mr. Kunal Kapoor and Mr. Yatharth Tripathi, Advs. versus UNION OF INDIA & ORS. ..... Respondents Through: Mr. Aditya Singla, SSC CBIC, Ms. Arya Suresh Nair & Ms. Medha Navami, Advs. (M: 7558898905) CORAM: JUSTICE PRATHIBA M. SINGH JUSTICE RAJNEESH KUMAR GUPTA Prathiba M. Singh, J. (Oral) 1. This hearing has been done through hybrid mode. 2. This writ petition is part of a batch of petitions that were filed under Article 226 of the Constitution of India, praying for a direction to quash refund proceedings initiated by the Directorate of Revenue Intelligence (‘DRI’) officials against the Petitioner/s on the ground that DRI officials lack jurisdiction under Section 28 of the Customs Act, 1962 . Reliance was primarily placed on the Supreme Court decision in Canon India Pvt. Ltd. v. Commissioner of Customs, 2021 (3) DWI 384 (hereinafter ‘Canon-I’), which had held that DRI Officials were not ‘proper officers’ for the purpose of refund proceedings under Section 2