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Issues: Whether the Customs authorities could continue to detain the petitioner's seized gold kada after expiry of the statutory period for issuing a show cause notice.
Analysis: The detention receipt itself identified the seized article as a gold kada weighing 76 grams, and that fact was not disputed. Under Section 110 of the Customs Act, 1962, once goods are detained, a show cause notice must be issued within the prescribed period, with extension permissible only in accordance with law. In the present case, the six-month period had expired, and no intimation of any lawful extension was shown to have been issued to the petitioner. The continued detention was therefore not permissible.
Conclusion: The detention was set aside, and the petitioner was entitled to return of the gold item within four weeks without storage charges.
Ratio Decidendi: Seized goods cannot be retained beyond the statutory period for issuance of a show cause notice unless a lawful extension is obtained and communicated in accordance with the Customs Act, 1962.