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    <title>2024 (1) TMI 901 - CESTAT AHMEDABAD</title>
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    <description>Customs demand, interest and penalty were challenged on limitation, with the extended period under the Customs Act found unavailable on the facts. The importer had furnished a country of origin certificate issued by the competent authority of the exporting country, and the customs authorities accepted the documents at clearance. As the relevant facts on origin and value addition lay within the exporting-country authority&#039;s domain and no suppression or mala fide conduct was shown, notice had to be issued within the normal limitation period. The notice was therefore time-barred, and the impugned order was set aside in favour of the assessee.</description>
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      <description>Customs demand, interest and penalty were challenged on limitation, with the extended period under the Customs Act found unavailable on the facts. The importer had furnished a country of origin certificate issued by the competent authority of the exporting country, and the customs authorities accepted the documents at clearance. As the relevant facts on origin and value addition lay within the exporting-country authority&#039;s domain and no suppression or mala fide conduct was shown, notice had to be issued within the normal limitation period. The notice was therefore time-barred, and the impugned order was set aside in favour of the assessee.</description>
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