Section 108 customs notices are not limited by Section 28 timelines; the summons-based challenge failed.

Notices issued under Section 108 of the Customs Act to summon persons, record evidence and require production of documents were not liable to be quashed on the basis of limitation under Section 28, because the impugned notices were not issued under Section 28. As no limitation period is prescribed for Section 108 notices, the challenge to their validity failed and the notices were upheld.

---

---

Issues: Whether notices issued under Section 108 of the Customs Act, 1962 were liable to be quashed on the ground that no notice under Section 28 of the Customs Act, 1962 had been issued within the asserted limitation period after seizure.

Analysis: The notices under challenge were issued for summoning the petitioners to appear, adduce evidence, and produce documents. The limitation argument based on Section 28 was held to be irrelevant because the impugned notices were not issued under that provision. For notices under Section 108, no limitation period was prescribed.

Conclusion: The challenge failed and the notices were upheld.

---