It was observed that the delay in the present case was marginal and that the petitioner could not be said to be grossly negligent in prosecuting its statutory remedy.

The Tribunal observed that revenue has compared the figures reflected in the ST-3 returns and figures reflected in Form 26AS statement and raised the demand without further examining the reasons for the difference in the two statements.

The Delhi High Court ruled that every Customs order must clearly name the officer who passed it, rejecting staff shortage as a valid excuse.