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of The matter pertains to the demand for differential customs duty on the undervaluation of goods cleared from a Special Economic Zone (SEZ) unit to the Domestic Tariff Area (DTA). Penalties were imposed on the appellant's SEZ unit and its DTA buyers. The key issues are: determining whether the SEZ unit or DTA buyer is liable for duty payment under SEZ and Customs Acts; verifying the costing methodology in the CAS-4 certificate submitted by the SEZ unit; considering factors like manufacturing facility size, turnover, clearance quantum, and product quality for applying comparable goods' pricing; and addressing the time-bar issue raised by the appellant. The Tribunal found the adjudicating authority's findings inadequate on these aspects and remanded the matter for reconsideration, directing the authority to provide elaborate findings addressing each defense raised by the appellants.
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