https://www.taxtmi.com/caselaws?id=767200 Delhi HC set aside a show cause notice (SCN) issued under Section 28(4) of the Customs Act after a prior SCN under Section 28(1) had been issued for similar factual circumstances. The court held that issuing two SCNs under different subsections for the same factual matrix is impermissible. The impugned SCN failed to satisfy Section 28(4) requirements regarding collusion or wilful misstatement, constituted a change of opinion by authorities within six weeks, and could not be considered a supplementary notice. The petition was allowed. en-us Fri, 07 Mar 2025 00:00:00 +0530 Sat, 28 Feb 2026 13:18:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=767200 Delhi HC set aside a show cause notice (SCN) issued under Section 28(4) of the Customs Act after a prior SCN under Section 28(1) had been issued for similar factual circumstances. The court held that issuing two SCNs under different subsections for the same factual matrix is impermissible. The impugned SCN failed to satisfy Section 28(4) requirements regarding collusion or wilful misstatement, constituted a change of opinion by authorities within six weeks, and could not be considered a supplementary notice. The petition was allowed. Case-Laws Customs Fri, 07 Mar 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=767200