Limitation under the Customs Act: court refused writ to quash a Show Cause Notice and directed authority to reassess the time bar defence.

Whether the High Court should quash a Show Cause Notice as time barred under the Customs Act was the central issue; the court refrained from exercising extraordinary writ jurisdiction and declined to rule on the limitation point where parallel authority proceedings and multiple parties exist. The court directed the authority to consider the petitioner's limitation defence and submitted precedents, including the Apex Court decision relied upon, and to decide the validity of the notice and any statutory extension in accordance with law. The petition to quash was dismissed.

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Issues: Whether the High Court should exercise its extraordinary writ jurisdiction to quash the Show Cause Notice dated 25 April 2025 on the ground that the notice is time barred for want of an extension under Section 110(2) of the Customs Act, 1962.

Analysis: The petition raises a contention that the Show Cause Notice is barred by limitation and that no show cause notice was issued for extension of the six month period prescribed under Section 110(2) of the Customs Act, 1962. The Court noted that proceedings under the Show Cause Notice involve multiple accused and that the petitioner has submitted a substantive reply alleging time bar and relying on precedent. Having considered the overlap with ongoing authority proceedings and the presence of other parties to the same Show Cause Notice, the Court refrained from adjudicating the limitation question on writ jurisdiction and directed the respondents-authority to consider the petitioner's explanation including the limitation defence in the light of the judgments relied upon by the petitioner and the subsequent Apex Court decision in Union of India v. Jatin Ahuja (11 September 2025).

Conclusion: The Court declined to exercise extraordinary writ jurisdiction to quash the Show Cause Notice and directed the respondents to consider the petitioner's reply on limitation and decide the matter in accordance with law.

Final Conclusion: The petition for quashing the Show Cause Notice is dismissed; the challenge to the Show Cause Notice on limitation grounds is left open for decision by the respondents-authority after considering the petitioner's submitted explanation and relevant precedents.

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