RIB TAPES (INDIA) PVT. LTD. & ANR. vs UNION OF INDIA & ORS.

The Supreme Court held that prior to the 1973 amendment, Section 111(m) of the Customs Act, 1962 did not permit penalties based on differences in value, as it referred to material particulars other than value. The Court quashed the penalty imposed on the appellants for breach of Section 111(m) and Section 111(d), stating that the unamended provision did not contemplate value differences as a basis for breach. The Court also clarified that the amendment introducing 'value' was not merely explanatory but a substantive change in the law.