Reopening assessments beyond four years requires nondisclosure of material facts; mere change of opinion or general allegations invalidates reassessme...
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Statutory interest on customs refund depends on whether the refund was processed within the period under Section 27A and whether any delay in re-assessment is attributable to the Department. Where refund claims became maintainable only after prior directions and the refund orders were issued within three months of the applications, the Court held that no interest was payable. By contrast, where petitioners had sought re-assessment long earlier and the Department's prolonged delay in passing re-assessment orders delayed the refund, the Court directed statutory interest from the date of the first re-assessment application until actual refund.
Statutory interest on customs refund depends on whether the refund was processed within the period under Section 27A and whether any delay in re-assessment is attributable to the Department. Where refund claims became maintainable only after prior directions and the refund orders were issued within three months of the applications, the Court held that no interest was payable. By contrast, where petitioners had sought re-assessment long earlier and the Department's prolonged delay in passing re-assessment orders delayed the refund, the Court directed statutory interest from the date of the first re-assessment application until actual refund.
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