https://www.taxtmi.com/caselaws?id=450590 Provisional assessments for imported goods made in 2011-13 could not be finalized by applying Rule 5 of the 2018 Regulations, which operates prospectively from 14-08-2018; finalization was governed by CBIC instructions requiring completion within six months, rendering finalization after 6-9 years time-barred, and the appellate finding on limitation was upheld. Separately, SCNs issued under s. 28 without mandatory pre-SCN consultation under the proviso to s. 28(1)(a) read with the 2018 consultation framework were invalid, and adjudication orders were also beyond the mandatory six-month period in s. 28(9)(a) (no extended period due to absence of suppression etc.); consequently, the SCNs, orders-in-original, and the impugned appellate order were quashed as void ab initio. en-us Mon, 04 Mar 2024 00:00:00 +0530 Mon, 22 Dec 2025 12:38:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=450590 Provisional assessments for imported goods made in 2011-13 could not be finalized by applying Rule 5 of the 2018 Regulations, which operates prospectively from 14-08-2018; finalization was governed by CBIC instructions requiring completion within six months, rendering finalization after 6-9 years time-barred, and the appellate finding on limitation was upheld. Separately, SCNs issued under s. 28 without mandatory pre-SCN consultation under the proviso to s. 28(1)(a) read with the 2018 consultation framework were invalid, and adjudication orders were also beyond the mandatory six-month period in s. 28(9)(a) (no extended period due to absence of suppression etc.); consequently, the SCNs, orders-in-original, and the impugned appellate order were quashed as void ab initio. Case-Laws Customs Mon, 04 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=450590