https://www.taxtmi.com/caselaws?id=784416 Extended limitation under the proviso to s.28(1) of the Customs Act was the dominant issue in a demand for differential duty based on rejection of transaction value under r.12 of the 2007 Valuation Rules and re-determination under r.3 read with s.14. The Tribunal held that clearance of Bills of Entry without valuation objection, followed by investigation nearly three years later, did not justify extended limitation absent evidence of wilful suppression or intent to evade duty. A statement recorded under s.108 admitting undervaluation was treated as insufficient and not determinative, and mere undervaluation was held inadequate to invoke the proviso. Consequently, the demand and impugned order were set aside and the appeal was allowed. en-us Tue, 09 Dec 2025 00:00:00 +0530 Mon, 05 Jan 2026 08:04:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784416 Extended limitation under the proviso to s.28(1) of the Customs Act was the dominant issue in a demand for differential duty based on rejection of transaction value under r.12 of the 2007 Valuation Rules and re-determination under r.3 read with s.14. The Tribunal held that clearance of Bills of Entry without valuation objection, followed by investigation nearly three years later, did not justify extended limitation absent evidence of wilful suppression or intent to evade duty. A statement recorded under s.108 admitting undervaluation was treated as insufficient and not determinative, and mere undervaluation was held inadequate to invoke the proviso. Consequently, the demand and impugned order were set aside and the appeal was allowed. Case-Laws Customs Tue, 09 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784416