https://www.taxtmi.com/caselaws?id=780003 Extended limitation under section 28(4) of the Customs Act applies only where non-levy or short-levy results from collusion, wilful misstatement, or suppression of facts with intent to evade duty; mere non-payment or a bona fide interpretative dispute is insufficient. On the facts described, disclosure to Customs and the absence of deliberate concealment meant the extended period could not be invoked for the pre-14.05.2015 demand. After the 14.05.2015 amendment to rule 2(bb) of the Legal Metrology (Packaged Commodities) Rules, imported parts supplied to industrial consumers, used for their own consumption and marked "not for retail sale," fell outside MRP-based assessment, so post-amendment demand was also unsustainable. en-us Tue, 09 Sep 2025 00:00:00 +0530 Wed, 15 Oct 2025 10:30:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780003 Extended limitation under section 28(4) of the Customs Act applies only where non-levy or short-levy results from collusion, wilful misstatement, or suppression of facts with intent to evade duty; mere non-payment or a bona fide interpretative dispute is insufficient. On the facts described, disclosure to Customs and the absence of deliberate concealment meant the extended period could not be invoked for the pre-14.05.2015 demand. After the 14.05.2015 amendment to rule 2(bb) of the Legal Metrology (Packaged Commodities) Rules, imported parts supplied to industrial consumers, used for their own consumption and marked "not for retail sale," fell outside MRP-based assessment, so post-amendment demand was also unsustainable. Case-Laws Customs Tue, 09 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780003