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Extended limitation for customs duty recovery under Section 28(4) requires material showing suppression, wilful misstatement, or another statutory basis. Where an importer supplied the SAFTA certificate of origin and other clearance documents, alleged defects in the certificate did not by themselves establish suppression. Proceedings initiated nearly five years after clearance lacked evidentiary support for invoking the extended period. The concurrent conclusion rejecting the extended limitation was maintained, and the Revenue's appeal was dismissed.
Extended limitation for customs duty recovery under Section 28(4) requires material showing suppression, wilful misstatement, or another statutory basis. Where an importer supplied the SAFTA certificate of origin and other clearance documents, alleged defects in the certificate did not by themselves establish suppression. Proceedings initiated nearly five years after clearance lacked evidentiary support for invoking the extended period. The concurrent conclusion rejecting the extended limitation was maintained, and the Revenue's appeal was dismissed.
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