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of The show cause notice issued on 17.10.2017 was governed by the unamended provisions of section 28(9) of the Customs Act. The unamended section provided time limits of six months or one year for determining duty/interest, where possible. The Commissioner recorded that despite issuing the notice, the appellant delayed filing a reply and sought documents, filing an interim reply only on 07.04.2021. Covid restrictions delayed proceedings till February 2021. After providing documents in March 2021 and a personal hearing on 03.06.2021, the matter was adjudicated on 29.06.2021. The Commissioner gave cogent reasons for inability to adjudicate within the unamended time limits. The appellant argued adjudication should have been within stipulated time despite no reply, but this aspect was examined. As no submissions were made on merits, only the limitation issue was considered. No infirmity was found in the Commissioner's order, and the appeals were dismissed.
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