https://www.taxtmi.com/caselaws?id=787462 Voluntary payment of differential customs duty during a DRI investigation, coupled with a request to close the investigation and no contemporaneous protest, attracts estoppel by conduct against a later refund claim. Notification No. 25/2019-Customs amended the earlier exemption notification prospectively and could not alter duty liability for earlier imports. Collection without a separate show cause notice was treated as proper where payment was voluntary and closure was sought under Section 28(2). Refund under Section 27 also requires proof that duty was not passed on to buyers; failure to disprove unjust enrichment prevents refund. en-us Wed, 25 Feb 2026 00:00:00 +0530 Fri, 06 Mar 2026 08:30:53 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787462 Voluntary payment of differential customs duty during a DRI investigation, coupled with a request to close the investigation and no contemporaneous protest, attracts estoppel by conduct against a later refund claim. Notification No. 25/2019-Customs amended the earlier exemption notification prospectively and could not alter duty liability for earlier imports. Collection without a separate show cause notice was treated as proper where payment was voluntary and closure was sought under Section 28(2). Refund under Section 27 also requires proof that duty was not passed on to buyers; failure to disprove unjust enrichment prevents refund. Case-Laws Customs Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787462