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CESTAT dismissed the appeals, sustaining invocation of the extended period of limitation and upholding denial of relief where the appellant relied on manipulated/forged Transport/Registration Authorizations (TRAs). The Tribunal held that the appellant's plea of ignorance of manipulation was untenable because statutory procedure required procurement of TRAs from the port of registration and verification of their authenticity; failure to apply to the issuing port and to verify documents constituted lack of due diligence. Consequently, the forgery of TRAs could not absolve the appellant, and relief was refused with appeals dismissed.