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Notice Defense & Litigation
Protecting the Balance Sheet

Customs Show Cause Notices (SCNs) routinely demand duty differentials plus 100% penalties, threatening corporate liquidity. With 42 years of technical customs adjudication experience, we dismantle departmental allegations and engineer massive demand reductions.

Led by Kuppusami: Former senior executive with over four decades handling complex valuation, classification, and DRI disputes.

60-85%
Average Demand Reduction
500+
Complex Cases Argued
42
Years Technical Experience

The Weaponization of Ambiguity

Customs law is deliberately complex. Investigating agencies exploit this ambiguity, invoking "suppression of facts" to extend limitation periods and levy maximum penalties on entirely legitimate business transactions.

Special Valuation Branch (SVB)

Importing from a related foreign parent inherently triggers SVB investigations. Failure to technically defend transfer pricing documentation results in "loading" of invoice values, forcing you to pay higher duties permanently.

Risk: Permanent 5-15% increase in landed costs.

DRI Investigations

Directorate of Revenue Intelligence (DRI) probes begin with aggressive unannounced searches and seizure of records. Statements recorded under Section 108 without legal counsel invariably become the foundation for massive tax demands.

Risk: 100% Penalties, asset seizure, and prosecution.

Classification Notices

Post-clearance audits identifying that your broker used a 7.5% duty code instead of the department's preferred 15% code. They invoke the extended period of limitation, demanding 5 years of differential duty instantly.

Risk: Crores in retrospective tax liabilities.

Confiscation Proceedings

Misdeclaration of quantity, value, or description can lead to the actual physical confiscation of your cargo at the port, throttling your supply chain and requiring heavy redemption fines to release the goods.

Risk: Production halts and loss of inventory.

Strategic Litigation Response

01

Adjudication Defense

Drafting highly technical replies to Show Cause Notices (SCNs). We dismantle departmental allegations using statutory interpretation, General Rules of Interpretation (GRIs), and establishing the absence of "mens rea" (intent to evade) to kill the 100% penalty provisions.

Personal Hearing RepresentationSVB Order Procurement
02

Appellate Tribunals

If the initial Adjudicating Authority rules against the importer, we escalate the matter to the Commissioner (Appeals) and the Customs, Excise and Service Tax Appellate Tribunal (CESTAT). We secure stay orders against coercive duty recovery during the pendency of the appeal.

Pre-deposit ManagementCESTAT Pleadings
03

Settlement Commission

When fighting is mathematically futile, we utilize the fast-track Settlement Commission route. We negotiate "full and true disclosures" to secure complete immunity from prosecution and obtain catastrophic penalty waivers (often reducing penalties to near zero).

Penalty MitigationProsecution Immunity
Case Study

Dismantling a Valuation SCN

Client Profile

  • • Mid-size Automotive Component Manufacturer
  • • Importing specific engine parts from a German parent company
  • • Paying a separate group royalty for "domestic manufacturing know-how"

The DRI Notice

  • • DRI alleged that the domestic royalty payments were implicitly related to the imported components.
  • • Issued an SCN under Rule 10(1)(c), demanding ₹1.74 Crores by "adding back" the royalty to the import value.
  • • Demanded an additional ₹1.74 Cr as a 100% equivalent penalty.

Our Execution

  • • Kuppusami tore down the technology transfer agreement clause by clause.
  • • Statutorily proved that the royalty was exclusively a condition of local sale of finished goods, NOT a condition of the import of components.
  • • Destroyed the "suppression" charge, eliminating the basis for the 100% penalty.
₹1.74 Cr
Original Department Demand
Dropped
100% Penalty Dismissed
₹28 L
Final Settlement Negotiated
84%
Total Liability Reduction

"When the DRI raid concluded, we thought the ₹3.5 Crore demand (duty + penalty) would shatter our quarterly cash flow. Mr. Kuppusami didn't panic. He systematically dissected their legal arguments, proved our royalty was purely domestic, and negotiated the total multi-year liability down to just 28 Lakhs."

— Managing Director, Auto Component JV

Questions & Answers

Litigation & Enforcement Protocols

Understanding SVB loading, DRI powers, and Settlement Commission physics.

SVB investigations are automatically triggered when you import goods from an overseas "related party" (e.g., your foreign parent company, a subsidiary, or a joint venture partner).

The Department's Suspicion:

Customs presumes that because the buyer and seller are related, the declared import price is artificially lowered to evade Indian Basic Customs Duty.

During the investigation (which can take 1-3 years), all your related-party imports are assessed Provisionally. You are often forced to pay Extra Duty Deposits (EDD) of 1% to 5% on every single shipment until the final SVB Order is issued.

Yes. A routine audit is an administrative check; a DRI investigation is an adversarial intelligence operation.

  • Customs Post-Clearance Audit (PCA): Generally scheduled, document-heavy, and focused on verifying classifications and exemptions claimed over the past year. Penalty exposure is usually limited if co-operation is provided.
  • Directorate of Revenue Intelligence (DRI): The apex anti-smuggling agency. Investigations often begin with unannounced premises raids, seizure of laptops/phones, freezing of bank accounts, and recording of statements under Section 108 of the Customs Act (which are admissible as evidence). They invariably allege "willful suppression" leading to 100% penalties and potential arrest.

Never answer a DRI summons without senior legal counsel prepping your statements and managing the documentary submissions.

The Settlement Commission is a strategic off-ramp for cases where the department's core evidence is legally unassailable and litigation failure is certain.

By voluntarily approaching the Commission and making a "full and true disclosure" of the duty liability, you gain massive protections:

  • 1. Complete immunity from prosecution under the Customs Act.
  • 2. Substantial waivers on applicable penalties (often reduced from 100% to 10% or zero).
  • 3. The case is closed decisively, preventing years of appellate friction.

Received a Show Cause Notice?

The first 48 hours dictate the final outcome. Do not submit any written responses to Customs or DRI without senior technical representation.