Quasi-judicial extension of time under customs law requires hearing and recorded sufficient cause before notice period is extended.

The power to extend time for issuing a show cause notice under Section 110(2) of the Customs Act is quasi-judicial, not mechanical, and requires a judicial approach based on sufficient cause and inquiry into relevant facts. The authority must give the affected party an opportunity to be heard before granting extension. On the stated facts, the extension was invalid because no hearing was afforded and the Collector merely recorded satisfaction without considering the petitioner's objections. The text also notes that the statutory maximum extension period had expired, leaving no scope for a fresh valid extension.

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Issues: Whether the order extending the time for issuing show cause notice under Section 110(2) of the Customs Act was valid when passed without giving the petitioner an opportunity of being heard.

Analysis: The power to extend the period for issuance of notice is not mechanical but quasi-judicial in nature and requires a judicial approach. An extension can be granted only on sufficient cause being shown, which contemplates some inquiry into the relevant facts and a determination by the authority on those facts. Since no opportunity was afforded to the petitioner to show cause against the proposed extension and the Collector merely recorded satisfaction without hearing him, the extension order was invalid. The statutory maximum period for extension had also expired, leaving no scope for a fresh valid extension.

Conclusion: The extension order was illegal and was liable to be quashed; the seized goods were directed to be returned to the petitioner.

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