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    <description>Disclosure of the cost certificate and price declaration defeated invocation of the extended limitation period, because the department had accepted the declared break-up and later could not allege suppression of cost elements already placed before it. The valuation-based demand also failed on revenue neutrality, as adoption of the higher assessable value would not have generated additional revenue on the record. The penalty on the employee-authorised signatory under Rule 209A was set aside because he acted only in the course of employment and there was no basis to show knowledge that the goods were liable to confiscation.</description>
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