The Show Cause Notice (SCN) issued after more than ten years is...

The Show Cause Notice (SCN) issued after more than ten years is time-barred, exceeding the extended period of limitation of five years provided u/s 28. The proposals in the SCN do not fall within the scope of Section 124, which allows notice for confiscation of goods and imposition of penalty. The only proposal falling u/s 124 is the imposition of penalty u/s 114, which cannot be sustained as there is no proposal to confiscate export goods or hold them liable for confiscation u/s 113, a prerequisite for imposing penalty u/s 114. The remaining proposals in the SCN fall beyond the scope of any SCN issued u/s 124. The Appellate Tribunal (CESTAT) is mentioned.

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