Valuation of goods for Customs duty should be done only at the time and place of importation and it should not be based on the bill of lading but on goods arriving in India. The Supreme Court rejected the argument of the Commissioner of Customs that the quantity mentioned in the bill of lading should be the basis of payment of duty, not the quantity actually received in this country. The Customs appellate tribunal had upheld the view of the Customs authorities, but the Supreme Court said that the tribunal had “ lost sight of the first principles”. It stated in its judgment, in Mangalore Refinery and Petrochemicals vs Commissioner of Customs, that the tribunal was wrong in holding that a levy in the context of import duty can only be on imported goods, that is, on goods brought into India from a place outside of India. Till that is done, there is no charge to tax. Explaining the law further, the judgment stated that the taxable event in the case of imported goods is “ import”. The tax