Limitation under Customs Act reference power turns on the goods release order, not later bond cancellation.

For limitation under Section 129D of the Customs Act, the relevant date was the order releasing the imported goods under the concessional notification, because that was the operative decision challenged as improper. The later cancellation of the bond was only ancillary to the clearance already granted and did not create a new, legally relevant starting point for limitation. On that basis, the Collector's direction under Section 129D(2) was held within time, and the Revenue's appeal failed.

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Issues: Whether the Collector's direction under Section 129D(2) of the Customs Act, 1962 was barred by limitation under Section 129D(3), and whether the relevant grievance date was the original release of the goods or the later cancellation of the bond.

Analysis: The relevant action for the purposes of Section 129D was the order releasing the imported goods under the concessional notification, because that was the operative decision said to be improper and the one requiring determination. The later cancellation of the bond did not furnish a meaningful or legally relevant starting point for limitation, since the bond was only ancillary to the clearance granted under the exemption and did not create the grievance that the Collector sought to challenge. The order directing reference was therefore founded on the date of release of the goods, and not on the subsequent bond cancellation.

Conclusion: The direction under Section 129D(2) was not time-barred, and the appeal by the Revenue failed.

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