Ajoy Nath Ray, J. - (1.) In this case the declaration was filed on 10-12-1998 and the refusal by the designated authority came in February and April, 1999.
(2.) The tax is direct tax by way of customs duty and the amount which was declared to be payable, being half the amount endorsed as a demand on the Bill of Entry was Rs. 3,27,804.69P.
(3.) In my opinion, the endorsement on the Bill of Entry is itself a demand and as such Section 87 of Part IV of the Finance (No. 2) Act, 1988 is attracted.;