https://www.taxtmi.com/caselaws?id=787691 Invocation of the extended limitation under Section 28(4) of the Customs Act was examined in relation to reclassification of imported plastic parts; the legal standard requires non-payment or short payment to result from collusion, willful misstatement or suppression of facts. The record relied on declaration omissions and expert opinion but contained no specific findings establishing culpable conduct. Because the dispute was primarily tariff classification arising from self-assessment and the requisite culpability was not demonstrated, the extended period could not be invoked and the demand raised beyond the normal limitation period is time-barred. en-us Mon, 09 Mar 2026 00:00:00 +0530 Tue, 10 Mar 2026 13:13:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787691 Invocation of the extended limitation under Section 28(4) of the Customs Act was examined in relation to reclassification of imported plastic parts; the legal standard requires non-payment or short payment to result from collusion, willful misstatement or suppression of facts. The record relied on declaration omissions and expert opinion but contained no specific findings establishing culpable conduct. Because the dispute was primarily tariff classification arising from self-assessment and the requisite culpability was not demonstrated, the extended period could not be invoked and the demand raised beyond the normal limitation period is time-barred. Case-Laws Customs Mon, 09 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787691