Challenge related to classification of imported goods - light...

Challenge related to classification of imported goods - light green tinted float glass under CTH 70052110 or CTH 70051010. Invocation of extended period of limitation examined. Issuance of notice prior to show cause notice regulated by Pre-Notice Consultation Regulations, 2018. Audit consultative letter received referring to waiver of show cause notice and penalty, indicating proceedings under sub-section (1) of section 28. Petitioner's replies not considered before issuing show cause notice under sub-section (4) of section 28. Petitioner imported light green float glass classifying under CTH 70051010 since 2011, not questioned earlier. Final assessments and appellate orders accepting classification not challenged. No reasons recorded for issuing consultative letter under sub-section (1) and then show cause notice under sub-section (4). Invoking enlarged period of limitation erroneous. Direction to clear goods under CTH 70051010 subject to appellate orders not being reversed.