Limitation for warehoused goods interest follows customs duty recovery logic, making belated demands time-barred.

Where the Customs Act, 1962 does not prescribe a specific limitation period for recovery of interest on warehoused goods, the demand must be raised within a reasonable time, and the limitation framework applied to customs duty recovery under Section 28 governs by analogy. Because the interest demand was issued well beyond six months after clearance of the goods, it was held time-barred. The assessee's reliance on the departmental public notice was also consistent with that position, so the lower authority's orders were sustained and the Revenue's appeal failed.

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Issues: Whether the demand for interest on warehouse goods could be enforced beyond six months and whether the limitation applicable to recovery of duty under the Customs Act, 1962 governed such demand.

Analysis: The demand related to interest payable on goods cleared from warehouse. No specific period of limitation was prescribed for recovery of such interest, and the legal approach adopted was that, where the statute is silent, recovery must be initiated within a reasonable period. The Tribunal applied the same scheme of limitation recognised for customs duty recovery under Section 28 of the Customs Act, 1962, and held that the same logic governed recovery of interest under the warehousing provisions. On the facts, the demand was raised well after six months from clearance of the goods. The plea based on estoppel was also consistent with the departmental position reflected in the public notice relied upon by the assessee.

Conclusion: The demand for interest was barred by limitation and the Revenue's appeal failed.

Final Conclusion: The orders of the lower authority were sustained and the revenue appeals were dismissed as the demand for interest could not be enforced beyond the applicable limitation period.

Ratio Decidendi: Where the Customs Act does not prescribe a specific period for recovery of interest on warehoused goods, the demand must be made within a reasonable period and, in the facts of this class of cases, the limitation applicable to Section 28 of the Customs Act, 1962 governs the recovery.

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