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    <title>2022 (4) TMI 988 - CESTAT CHENNAI</title>
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    <description>Advance DTA sale permitted by the Development Commissioner had to be credited while quantifying any alleged excess DTA clearances, because entitlement could not be reworked as if that permission had never been granted. Deemed exports between 100% EOUs were to be treated as exports for FOB computation of DTA sale entitlement, and a departmental circular could not override that settled position. The extended limitation period was unavailable where the clearances were reflected in records and periodic disclosures, with no suppression or wilful misstatement shown. On that basis, the duty demand, penalties, and confiscation findings were unsustainable.</description>
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