https://www.taxtmi.com/caselaws?id=783481 Section 149 of the Customs Act permits conversion of shipping bills on documentary proof and does not itself prescribe a limitation period. The three-year restriction could not be read into the provision, and Article 137 with section 29(2) of the Limitation Act was held inapplicable to conversion proceedings before a tribunal or quasi-judicial authority. A circular cannot impose a restriction inconsistent with the statute, so Clause 3(e) of Circular No. 36/2010-Cus. could not justify refusal of conversion. The discussion also notes the relevance of merger and finality in preventing collateral challenge to an earlier conversion order. en-us Mon, 15 Dec 2025 00:00:00 +0530 Wed, 17 Dec 2025 15:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783481 Section 149 of the Customs Act permits conversion of shipping bills on documentary proof and does not itself prescribe a limitation period. The three-year restriction could not be read into the provision, and Article 137 with section 29(2) of the Limitation Act was held inapplicable to conversion proceedings before a tribunal or quasi-judicial authority. A circular cannot impose a restriction inconsistent with the statute, so Clause 3(e) of Circular No. 36/2010-Cus. could not justify refusal of conversion. The discussion also notes the relevance of merger and finality in preventing collateral challenge to an earlier conversion order. Case-Laws Customs Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783481