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    <title>SAD exemption and limitation: stock transfer from FTWZ failed the sale condition, but demand was quashed as time-barred.</title>
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    <description>Exemption from Special Additional Duty under Notification No. 45/2005-Customs was held unavailable where imported bulk tablets were moved from an FTWZ to the importer&#039;s factory by stock transfer, because sale on payment of Sales Tax/VAT was a condition precedent and was not satisfied at the clearance stage. However, the demand was set aside as time-barred: the Tribunal found that the record disclosed the nature of the activity and the parties&#039; understanding of the notification, so non-payment of duty could not be treated as suppression, wilful misstatement or similar conduct to justify the extended limitation period under Section 28. The appeals were allowed solely on limitation.</description>
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    <pubDate>Sat, 28 Mar 2026 08:57:27 +0530</pubDate>
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      <title>SAD exemption and limitation: stock transfer from FTWZ failed the sale condition, but demand was quashed as time-barred.</title>
      <link>https://www.taxtmi.com/highlights?id=98171</link>
      <description>Exemption from Special Additional Duty under Notification No. 45/2005-Customs was held unavailable where imported bulk tablets were moved from an FTWZ to the importer&#039;s factory by stock transfer, because sale on payment of Sales Tax/VAT was a condition precedent and was not satisfied at the clearance stage. However, the demand was set aside as time-barred: the Tribunal found that the record disclosed the nature of the activity and the parties&#039; understanding of the notification, so non-payment of duty could not be treated as suppression, wilful misstatement or similar conduct to justify the extended limitation period under Section 28. The appeals were allowed solely on limitation.</description>
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