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    <title>2024 (3) TMI 1036 - CESTAT HYDERABAD</title>
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    <description>Classification of bio-fertilisers, single micronutrients, multi-micronutrients and plant growth regulators remained disputed during the relevant period, and a prior Board circular had already clarified the issue in April 2016. On that basis, the demand was not sustainable for the extended period of limitation, as the notice was treated as reflecting a change of opinion rather than suppression or wilful misstatement. The classification questions under competing tariff headings were remanded for fresh adjudication by the Original Authority for the normal period, with liberty to adduce evidence, legal submissions and, if sought, cross-examine the Chemical Examiner. Penalties on the company and its Director were set aside as they were linked to the same bona fide classification dispute.</description>
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