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of CESTAT held that the show-cause notice invoking the extended limitation under s.28, Customs Act, 1962, was time-barred and declined to adjudicate the merits. The tribunal noted departmental ambiguity on tariff classification of TV tuners during the relevant period and that the impugned order itself adopted a different CTH than initially assessed. Applying the principle that a time-barred demand precludes merit adjudication, as affirmed by higher courts, CESTAT set aside the impugned order and allowed the appeal, thereby quashing the demand insofar as it was raised beyond the statutory period against the Appellant and dismissing the Revenue's extended limitation plea.
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