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    <description>Differential customs duty recovery was considered unsustainable where imports were cleared after customs examined the advance licence and extended exemption benefit, and the later notice was issued only after clearance on an allegation of suppression. The record showed that both the importers and the department proceeded on the same understanding that compliance with the value restriction was sufficient, with no material indicating misstatement or concealment by the importers. On that basis, the demand was treated as barred by limitation, and the proposed penalties on the importing firms&#039; employees and the broker also failed for want of a valid foundation.</description>
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