UNION OF INDIA & ORS. vs M/S. RAI BAHADUR SHREE RAM DURGA PRASAD (P)LTD. & ORS.

The Supreme Court held that under Section 12(1) of the Foreign Exchange Regulation Act, 1947, the requirement for exporters to declare the full export value is a penal provision, and its interpretation must not extend beyond its clear language. The Court found that the respondents had complied with the statutory requirements by providing a declaration to the Collector of Customs, and thus could not be penalized under Section 167(8) of the Sea Customs Act for undervaluation. The appeal was allowed, overturning the High Court's decision that had favored the imposition of a penalty.