This compilation indexes twelve orders issued by the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) between January 2025 and May 2026 in which Section 112 of the Customs Act, 1962 — the general penalty provision for improper importation or exportation — was among the sections engaged. The cases span CESTAT benches at Bangalore, Hyderabad, Chennai, New Delhi, Allahabad, Kolkata, and Mumbai, and arise from a diverse range of fact patterns including defence-equipment imports, alleged gold smuggling, goods mis-declaration, and differential duty demands. The compilation is intended for customs law practitioners, in-house legal teams, and tax researchers who need a structured index of recent CESTAT activity on this provision.

Research index only. This page is a structured case-law reference compiled from tribunal orders. It does not constitute legal advice, and nothing here should be relied upon as guidance for any specific transaction or dispute. Readers should consult the full text of each judgment and verify current status before use.

The statutory framework in one paragraph

Section 112 of the Customs Act, 1962 prescribes penalties for acts and omissions relating to improper importation or exportation of goods. In broad terms, the provision empowers adjudicating authorities to impose a monetary penalty on any person who, in relation to any goods, does or omits to do any act that renders the goods liable to confiscation under the Act, or who acquires possession of, or is in any way concerned in carrying, removing, depositing, harbouring, keeping, concealing, selling or purchasing, or in any other manner dealing with goods which such person knows or has reason to believe are liable to confiscation. The quantum of penalty is tied to the value of the goods or the duty sought to be evaded, and sub-sections (a) and (b) of Section 112 address principal offenders and other persons respectively. Section 112 is frequently read alongside Section 111 (confiscation of improperly imported goods), Section 114A (penalty for short-levy or non-levy of duty in cases involving fraud or collusion), and Section 125 (option to pay fine in lieu of confiscation), which together constitute the core penalty-and-confiscation framework under the Customs Act, 1962.

The 12 rulings

1. Bharat Electronics Limited vs The Principal Commissioner Of Customs -

Bench: Custom, Excise & Service Tax Tribunal
Date: 5 May 2026
Sections engaged: 112, 28(4), 28A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Customs Appeal No. 20295 of 2025) was filed before the CESTAT Bangalore Regional Bench against Order-in-Original Sl. No. 543/2024-25 AP & ACC dated 20.12.2024 passed by the Commissioner of Customs, Bengaluru. Per the source preview, the appellant is a Public Sector Undertaking engaged in manufacture of electronic products and systems for the Army, Navy, and the Air Force, and was nominated by the Ministry of Defence as a lead integrator for the Long Range Surface-to-Air Missile System for installation on board Navy ships; the imports involved the LRSAM System sourced from Israel Aerospace Industries for onward supply to shipbuilders constructing vessels for the Ministry of Defence. The appeal engages the penalty and duty-recovery provisions cited above; the full outcome is not captured in the available source extract.

2. Shri Senthil Kumar Anbalagan vs Hyderabad - Customs

Bench: Custom, Excise & Service Tax Tribunal
Date: 18 March 2026
Sections engaged: 101, 108, 111, 112, 123, 138B, 77
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Customs Appeal No. 30558 of 2025) was filed before the CESTAT Hyderabad Single Member Bench against Order-in-Appeal No. HYD-CUS-000-APP1-061-24-25 dated 26.02.2025. Per the source preview, the appellant arrived from Singapore to Hyderabad by Fly Scoot Flight No. TR-574 on 15.02.2020, was intercepted by CISF officials at RGI Airport after passing through the green channel, and was found carrying four packets of gold in paste form concealed on his body — two packets each weighing 200 grams recovered from his socks and two packets each weighing 350 grams recovered from his undergarments. The multiple sections engaged reflect the range of customs offence and procedural provisions typically invoked in passenger-smuggling matters; the full outcome is not captured in the available source extract.

3. Commissioner Of Customs Preventive - vs P.R.Mohanlal

Bench: Custom, Excise & Service Tax Tribunal
Date: 23 January 2026
Sections engaged: 108, 110, 111(d), 112(b), 114, 114A, 123, 124
Outcome: Outcome not specified in source
Procedural / substantive ground: The lead appeal (Customs Appeal No. 20837 of 2024) was filed before the CESTAT Bangalore Regional Bench by the Commissioner of Customs (Preventive) against Order-in-Appeal No. COC-CUSTM-PRV-APP-34 to 37-2024-25 dated 13.05.2024 passed by the Commissioner of Central Excise (Appeals), Kochi; three connected appeals (Nos. 20592, 20593, and 20594 of 2025) concerning Shri M R Ranjith, Shri Jaison Baby, and Shri Dinesh Kumar were heard together. The respondent in the lead appeal is Shri P.R. Mohanlal alias Shaji, Proprietor of M/s. Vajra Jewels, Thrissur; the revenue department is the appellant, suggesting a challenge to relief granted at the first-appellate stage. The full outcome is not captured in the available source extract.

4. Mamta Enterprises vs Principal Commissioner, Customs

Bench: Custom, Excise & Service Tax Tribunal
Date: 12 December 2025
Sections engaged: 111, 112, 114A, 125, 17, 28
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Customs Appeal No. 51306 of 2023) was filed before the CESTAT New Delhi Principal Bench against Order-in-Appeal No. CC(A)CUS/D-II/ICD/TKD/Import/1211/2022-2023 dated 12.12.2022. Per the source preview, the first appellate authority had upheld the order passed by the Joint Commissioner dated 04.08.2022 but set aside the penalties imposed under Section 114A of the Customs Act and instead imposed a penalty of Rs. 40,000/- under Section 112 of the Act; the appellant had filed Bill of Entry No. 9393418 dated 04.07.2022 to clear "car curtain/curtain accessories" classifying them under Customs Tariff Item 6303 99 90. The appeal before CESTAT thus arises from the first appellate authority's substitution of the Section 114A penalty with a Section 112 penalty, and the classification dispute over the imported goods.

5. Amit Bhutoria vs Kolkata-Admn Airport

Bench: Custom, Excise & Service Tax Tribunal
Date: 2 December 2025
Sections engaged: 108, 112(b), 114A, 77
Outcome: Outcome not specified in source
Procedural / substantive ground: Two connected appeals (Customs Appeal Nos. 75778 and 75779 of 2023) were filed before the CESTAT Eastern Zonal Bench, Kolkata against Order-in-Appeal Nos. KOL/CUS/AIRPORT/KS/495/2023 and KOL/CUS/AIRPORT/KS/494/2023 both dated 30.06.2023 passed by the Commissioner of Customs (Appeals), Kolkata; Final Orders Nos. 77825-77826/2025 were pronounced on 02.12.2025 after hearing on 21.11.2025. The source preview records that the captioned appeals were filed by the same appellant from an address at Salt Lake City, Kolkata; the sections engaged — including the penalty sub-provisions — indicate the matter concerns passenger or airport-related customs infractions. The full outcome is not captured in the available source extract.

6. Chennai (Port Export) vs Usha Bhandari

Bench: Custom, Excise & Service Tax Tribunal
Date: 6 November 2025
Sections engaged: 111, 112, 14, 28(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three connected appeals (Customs Appeal Nos. 41541, 41542, and 41547 of 2013) were heard together before the CESTAT Chennai Regional Bench; the order was pronounced in open court on 06.11.2025. Per the source preview, the appeals arise from Order-in-Original No. 20669/2013 dated 22.03.2013 passed by the Commissioner of Customs, Chennai, and involve M/s. Surya Prakash Bhandari and Smt. Usha Bhandari (Proprietrix of Rajguru Industries), both of No. 24, Narayana Mudali Street, Chennai, as appellants in their respective appeals against the Commissioner of Customs, Chennai II Import Commissionerate. The sections engaged indicate the dispute involves valuation, confiscation, penalty, and duty-demand provisions; the full outcome is not captured in the available source extract.

7. Mahabir Prasad Sharma vs Commissioner Of Customs - Chennai Ii

Bench: Custom, Excise & Service Tax Tribunal
Date: 26 September 2025
Sections engaged: 112(a), 114A, 125, 28(4)
Outcome: Outcome not specified in source
Procedural / substantive ground: Three connected appeals (Customs Appeal Nos. 40549, 40553, and 40610 of 2024) were heard together before the CESTAT Chennai Regional Bench; all three arise from Order-in-Original No. 106063/2024 dated 05.04.2024 passed by the Commissioner of Customs, Chennai II. Per the source preview, the appellants in the connected matters are M/s. Ocean Sky Impex Pvt. Ltd. (No. 33/4, North Street, Venkatesh PU, Ayanavaram, Chennai), its Managing Director Mr. V. Karthik, and Mr. Mahabir Prasad Sharma (R/o Flat No. 57, Bharat Apartment, Sector-13, Rohini, North West, Delhi). The sections engaged — including the penalty sub-provision and the duty-recovery provisions — indicate the matter involves both confiscation-linked penalty and duty-demand issues; the full outcome is not captured in the available source extract.

8. Anil Agarwal vs C.C. Noida

Bench: Custom, Excise & Service Tax Tribunal
Date: 9 September 2025
Sections engaged: 108, 111, 112(a), 114A, 12(a), 125, 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: Six connected appeals (Customs Appeal Nos. 70502 to 70507 of 2022) were heard together before the CESTAT Allahabad Regional Bench (Court No. II) via e-hearing; Final Orders Nos. 70627-70632/2025 were issued on 09.09.2025 after hearing on 17.07.2025. Per the source preview, the appeals are directed against Order-in-Original No. 13/PR.COMMR./NOIDA-CUS/2022-23 dated 29.07.2022 passed by the Principal Commissioner of Customs, ICD Dadri, Noida; the appellants across the batch include Shri Kush Agarwal (Director, M/s Padam Parmeshwari Venture Pvt. Ltd.), Manoranjan Kumar, Chandan Chaudhary, Anil Agarwal, Pratul Khanna, and Pankaj Khanna. The breadth of sections engaged reflects the multi-party, multi-charge nature of the proceedings.

9. Anil Agarwal vs C.C. Noida

Bench: Custom, Excise & Service Tax Tribunal
Date: 3 July 2025
Sections engaged: 108, 110, 111, 112(a), 114A, 12(a), 125, 14A
Outcome: Outcome not specified in source
Procedural / substantive ground: Six connected appeals (Customs Appeal Nos. 70469 to 70474 of 2022) were heard before the CESTAT Allahabad Regional Bench (Court No. I) against Order-in-Original Nos. 12/PR.Commr./Noida-Cus/2022-23 dated 29.07.2022 of the Commissioner of Customs (Preventive), Noida; the appellants include Mr. Anil Agarwal (Manager & Authorised Representative, M/s Padam Parmeshwari Ventures Pvt. Ltd., D-122, Bulandshahar Indl. Area, Ghaziabad), Mr. Kush Agarwal, Mr. Chandan Chaudhary, Mr. Manoranjan Kumar, Mr. Pankaj Khanna, and Mr. Pratul Khanna. Per the source preview, the underlying order included a confiscation finding in respect of goods concerning country of origin and violations of the Food Safety and Standards (Packing and Labelling) Regulation, 2011, and since the goods were not available for confiscation having been disposed of by auction sale, a Redemption Fine of Rs. 1,00,000/- (Rupees One Lakh only) was imposed.

10. Giirish Mitruka vs C.C. Lucknow

Bench: Custom, Excise & Service Tax Tribunal
Date: 5 May 2025
Sections engaged: 111(b), 112(b), 11A, 121, 122A, 138B, 2(39), 7(1)
Outcome: Outcome not specified in source
Procedural / substantive ground: Two connected appeals (Customs Appeal Nos. 70305 and 70306 of 2022) were heard before the CESTAT Allahabad Regional Bench (Court No. I); Final Orders Nos. 70251-70252/2025 were issued on 05.05.2025 after hearing on 19.02.2025. Per the source preview, the appeals arise from Order-in-Original No. 09/Commissioner/LKO/2021-22 dated 11.04.2022 passed by the Commissioner, Customs (Preventive), Lucknow; the Directorate of Revenue Intelligence, Lucknow Zonal Unit, on the basis of specific intelligence, seized 3499.750 grams of foreign origin gold, valued at Rs. 1,73,93,757/-, on 13.02.2021 from the possession of an individual, and the appellants Girish Mitruka and Harish Mitruka are connected to that seizure. The range of sections engaged reflects the multi-limb legal framework invoked in gold-seizure matters involving foreign-origin goods.

11. Ashiquzzaman vs Commissioner Of Customs Air Special

Bench: Custom, Excise & Service Tax Tribunal
Date: 24 March 2025
Sections engaged: 111, 112, 114A, 155(2)
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Customs Appeal No. 85945 of 2020) and a connected Cross-Objection (No. 85419 of 2020 on behalf of the respondent) were heard before the CESTAT Mumbai West Zonal Bench; the appeal arises from Order-in-Appeal No. MUM-CUSTM-APSC-APP-336/20-21 dated 11th September 2020 passed by the Commissioner of Customs (Appeals), Mumbai Zone-III. Per the source preview, the proceedings involve the hierarchy of officers of customs under Section 3 of the Customs Act, 1962, empowered at customs stations for assessment and clearance of imported and export goods, prevention of prohibited goods, and recovery of duties; the matter engages both penalty provisions and the correction-of-clerical-error provision. The full substantive outcome is not captured in the available source extract.

12. Madhepura Electric Locomotive Private vs -Kolkata(Port)

Bench: Custom, Excise & Service Tax Tribunal
Date: 27 January 2025
Sections engaged: 112, 114A, 17, 28(4), 28A
Outcome: Outcome not specified in source
Procedural / substantive ground: The appeal (Customs Appeal No. 75445 of 2021) was filed before the CESTAT Eastern Zonal Bench, Kolkata; Final Order No. 75210/2025 was issued on 27.01.2025. Per the source preview, the appeal is against an impugned order (Order-in-Original No. KOL/CUS/PR.COMMR/PORT/08/2021 dated 17.02.2021) demanding differential IGST along with interest and imposing redemption fine and penalty; the appellant, M/s. Madhepura Electric Locomotive Pvt. Ltd. (a joint venture between Alstom Transport India Ltd. and Indian Railways), is engaged in the manufacture and supply of electric locomotives to the Indian Railways. The sections engaged — covering self-assessment, demand, interest, and penalty — are consistent with a differential-duty-and-IGST demand matter in the context of a capital-goods import.

Patterns across these 12 rulings

Concurrent invocation of Section 112 with Section 114A. Across the majority of cases in this compilation — including Cases 3, 4, 5, 7, 8, 9, 11, and 12 — Section 112 is cited alongside Section 114A. This reflects the established practice of adjudicating officers framing charges under both the general penalty provision and the specific fraud/collusion/wilful misstatement penalty provision, with the first appellate stage (as seen in Case 4) sometimes substituting one for the other.
Penalty alongside confiscation and redemption fine. Cases 4, 8, 9, and 12 demonstrate the recurring pattern of combined orders under confiscation, redemption fine, and penalty provisions. In Case 9, the source preview records the imposition of a Redemption Fine of Rs. 1,00,000/- in a situation where the goods had already been disposed of by auction and were unavailable for physical confiscation — illustrating how redemption fine provisions operate even when the goods are no longer available.
Multi-party and batch proceedings. Cases 8 and 9 each involve six connected appeals arising from a single Order-in-Original; Case 3 involves four connected appeals; and Case 7 involves three connected appeals. Batch adjudication of this kind — where a single enforcement action generates penalty proceedings against multiple individuals — is a recurring structural feature across the CESTAT orders in this compilation.
Gold and precious metal seizures as a distinct cluster. Cases 2, 3, and 10 all involve gold or gold-related goods. Case 2 concerns gold in paste form concealed on a passenger's body at an airport; Case 10 concerns seized foreign-origin gold; and Case 3 involves Vajra Jewels. The sections engaged in these matters (including Section 123 on reverse burden of proof for notified goods) are consistently broader than in straightforward mis-declaration cases, reflecting the specialised evidentiary and penalty framework applicable to precious metals.
Defence and public-sector imports as a distinct category. Cases 1 and 12 both involve imports by entities connected to national defence or Indian Railways. Case 1 concerns a PSU importing a defence system for the Indian Navy; Case 12 concerns a joint venture company supplying electric locomotives to Indian Railways. The involvement of government-linked entities and the nature of the imported goods may raise distinct considerations regarding exemption claims and duty treatment, which is reflected in the specific sections engaged (including Sections 28(4), 28A, and 17) in those two cases.

How to use this compilation

This compilation is a structured index intended to help researchers identify CESTAT proceedings in which Section 112 of the Customs Act, 1962 was engaged during the period January 2025 to May 2026. Because all twelve outcome fields record "Outcome not specified in source," users should treat this index as a starting point for locating the full text of each order rather than as a statement of the final legal position. Researchers should retrieve the complete judgment from indiankanoon.org, the official CESTAT portal, or a primary legal database before drawing any conclusions about the ratio, holding, or precedential value of a particular order.

Users should also check whether any of the listed orders have been subsequently challenged, stayed, or reversed by a High Court or the Supreme Court. CESTAT orders in customs penalty matters are routinely the subject of further appeals under Section 130 of the Customs Act (reference to High Court) or directly under Article 226/227 of the Constitution. A final CESTAT order is not necessarily the last word, and an order with "Outcome not specified in source" may have been disposed of by remand, partial relief, or stay pending a higher court proceeding.

Finally, researchers should cross-check relevant CBIC circulars, instructions, and Board-level clarifications that may have been issued on the substantive questions arising in these cases — including circulars on valuation methodology, classification of specific goods, the interaction between Section 112 and Section 114A penalties, and the treatment of goods that have already been auctioned or destroyed. Statutory provisions and Board instructions are the primary legal material; this compilation is a secondary research aid only.

Source

All cases listed above are drawn from the TaxNoticeAI structured legal corpus (16,101 Indian tax judgments, CBIC circulars, ITAT rulings, AAR rulings, GSTAT rulings), sourced from indiankanoon.org and official court portals.

Customs Act Section 112 Penalty: 12 CESTAT Rulings (2025-2026)