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    <description>The Tribunal&#039;s consideration of additional material in appeal was treated as a technical objection because the material was examined for classification and exemption issues, caused no prejudice to the Revenue, and did not undermine the correctness of the determination. Extended limitation under customs law was not attracted because Section 28(4) requires collusion, wilful misstatement, or suppression of facts, and a later change of view on classification or exemption was insufficient to establish that mental element. As the extended period failed, the consequential penalty linked to it also could not stand, and the challenge on limitation was rejected.</description>
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