https://www.taxtmi.com/caselaws?id=42749 The Supreme Court held that the limitation prescribed by Section 28 does not apply to actions taken by the Central Government under Section 131(3) of the Customs Act. The Court clarified that Section 28's limitation is relevant for actions under Section 131(5) against the original assessing authority's orders, not for annulment or modification under Section 131(3). As the show-cause notice sought to annul/modify the Appellate Collector's order under Section 128, it was not time-barred. The dissenting opinion by Justice Punchhi argued that the Central Government's power under Section 131(3) should be exercised within the time limit set by Section 28. en-us Fri, 04 May 1990 00:00:00 +0530 Mon, 21 Jul 2014 12:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=42749 The Supreme Court held that the limitation prescribed by Section 28 does not apply to actions taken by the Central Government under Section 131(3) of the Customs Act. The Court clarified that Section 28's limitation is relevant for actions under Section 131(5) against the original assessing authority's orders, not for annulment or modification under Section 131(3). As the show-cause notice sought to annul/modify the Appellate Collector's order under Section 128, it was not time-barred. The dissenting opinion by Justice Punchhi argued that the Central Government's power under Section 131(3) should be exercised within the time limit set by Section 28. Case-Laws Customs Fri, 04 May 1990 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=42749