Imports under TRQ with bills of lading by 31 March 2023, landed by 30 June 2023, qualify for duty refund.

The petitioner imported crude soybean oil under Bill of Entry No. 5592705 dated 20 April 2023 and sought a refund of excess customs duty paid on the consignment.

Its representation dated 20 January 2026 was rejected by the respondent authorities through letter No. F/No.S/6-Misc/Refund/2020-21 dated 6 February 2026.

The petitioner challenged the rejection under Article 226 of the Constitution.

The petitioner had earlier approached the Delhi High Court, but its writ petition was rejected for want of territorial jurisdiction on 8 April 2026, leading to the present proceedings before the Gujarat High Court.

The respondents did not dispute the settled legal position.

Whether the petitioner was entitled to the benefit of the TRQ-related customs duty exemption and consequential refund of excess duty paid on crude soybean oil imported under Bill of Entry No. 5592705 dated 20 April 2023?

Whether the respondent authority’s letter dated 6 February 2026 rejecting or declining the petitioner’s refund claim was liable to be quashed?

Whether the Revenue was required to process and grant the refund in accordance with law pursuant to the binding principles laid down in Ajanta Soya Ltd. and the subsequent Delhi High Court judgment concerning the petitioner?

The Court exercised jurisdiction under Article 226 of the Constitution to examine the legality of the refund rejection.

It applied the TRQ framework governing imports of crude soybean oil, including the DGFT Public Notice dated 24 May 2022, the subsequent Public Notice dated 11 January 2023, and the Ministry of Finance’s notifications dated 24 May 2022, 3 March 2023 and 10 May 2023.

Under the principle stated in Ajanta Soya Ltd. v. Union of India , 2024 SCC OnLine Del 1585, where the Bill of Lading was dated on or before 31 March 2023 and the goods landed before 30 June 2023, the TRQ benefit and corresponding exemption from customs duty and AIDC continued to apply.

The challenge to Ajanta Soya Ltd. before the Supreme Court was dismissed in SLP (Civil) Diary No. 54950 of 2024 on 16 December 2024.

The Court found that the petitioner’s claim was squarely covered by the Delhi High Court’s decision dated 6 October 2025 concerning the same importer, product and relevant period.

The legal position emerging from Ajanta Soya Ltd. was that the TRQ benefit stood extended until 30 June 2023, and imports covered by Bills of Lading dated on or before 31 March 2023 were eligible for the exemption if the goods landed before 30 June 2023.

Applying that principle to the petitioner’s import and the earlier decision concerning its substantially identical claim, the Court held that the refusal to process the refund was legally unsustainable.

The respondents were unable to dispute the settled position, and therefore the impugned communication could not be sustained.

It allowed the writ petition and directed the Revenue to process the petitioner’s refund claim in accordance with law within three months from receipt of the order.

The connected civil application for production of additional evidence was consequently disposed of.