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CESTAT Chennai addressed undervaluation of imported glass sheets. The revenue invoked an extended period of limitation due to significant discrepancies in declared value vs. contemporaneous imports. However, the tribunal held that for such an extension, fraud or willful misstatement must be proven. The revenue failed to provide concrete evidence justifying rejection of declared value u/r 3 of Customs Valuation Rules. No incriminating documents were found during investigation. The revenue's case based on comparable imports lacked merit as no comparable cases were identified. The tribunal set aside the demand, impugned order, and penalties, granting appeal with consequential benefits.
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