In Brief
Two importers challenged Customs Duty demands after purchasing forged DEPB (Duty Entitlement Passbook) Scripps and Transfer Release Advices, claiming the extended assessment period could not be invoked without proof of intentional fraud. The Supreme Court held that forged documents are void ab initio, and fraud vitiates everything. When importers obtain exemption benefits using forged documents, they remain liable for Customs Duty regardless of knowledge or intent. The Court distinguished the question of penalty (where knowledge matters) from substantive duty liability (where it does not). Both appeals were dismissed, with the Court directing completion of pending penalty proceedings within six months.
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