https://www.taxtmi.com/caselaws?id=787293 Extended limitation under Section 28(4) applies only where non-levy or short-levy results from collusion or deliberate wilful suppression intended to evade duty; mere misclassification, bona fide belief in tariff classification based on supplier documents, or payment of differential duty before show cause notices does not establish such intent. Self-assessment obligations do not automatically convert classification disputes into willful suppression because officers must also scrutinize declarations. On these facts there was insufficient material of deliberate suppression; therefore invocation of the extended period and consequent confiscation and penalty were unsustainable and set aside, with the appeal allowed. en-us Fri, 27 Feb 2026 00:00:00 +0530 Mon, 02 Mar 2026 08:34:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787293 Extended limitation under Section 28(4) applies only where non-levy or short-levy results from collusion or deliberate wilful suppression intended to evade duty; mere misclassification, bona fide belief in tariff classification based on supplier documents, or payment of differential duty before show cause notices does not establish such intent. Self-assessment obligations do not automatically convert classification disputes into willful suppression because officers must also scrutinize declarations. On these facts there was insufficient material of deliberate suppression; therefore invocation of the extended period and consequent confiscation and penalty were unsustainable and set aside, with the appeal allowed. Case-Laws Customs Fri, 27 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787293