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CESTAT dismissed the appeal, upholding the Commissioner's order extending time under the proviso to section 110(2) of the Customs Act, 1962. The Tribunal found no breach of natural justice: an SCN proposing the extension was served, the appellant's submissions were recorded and considered (paras 15-16), and reasons for extension were expressly stated. Material reasons included the appellant's non-cooperation, failure to respond to summons, and active delay of the investigation, together with the need to verify multiple factors including potential contraventions under the Foreign Trade (Development & Regulation) Act, 1992. The extension was held to be justified on the facts and in law; appeal dismissed.