Extension of time for customs show-cause notice upheld where incomplete investigation and unexplained seized material justified further inquiry

Sufficient cause existed to extend the period for issuing a show-cause notice under the proviso to Section 110(2) of the Customs Act, 1962. The extension was justified because the investigation remained incomplete due to the appellant's lack of cooperation, failure to retrieve seized computer data, and absence of an explanation for the source of the seized goods and cash. The Tribunal accepted that the Commissioner had recorded proper satisfaction on these grounds and that the appellant had not rebutted the need for further inquiry. The extension of time was upheld and the challenge to the order failed.

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Issues: Whether sufficient cause existed for extending the period for issuance of show-cause notice under the proviso to Section 110(2) of the Customs Act, 1962.

Analysis: The extension was sought on the ground that investigation could not be completed because the appellant did not cooperate, the seized computer data could not be retrieved, and the source of the seized goods and cash was not explained. The Tribunal found that the Commissioner had recorded satisfaction on these grounds and that the appellant had not rebutted the basis for further investigation. The Tribunal also noted that the unexplained seizure material supported the need for continued inquiry.

Conclusion: The extension of time for issuance of the show-cause notice was upheld and the challenge to the impugned order failed.

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