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    <title>2026 (4) TMI 880 - CESTAT KOLKATA</title>
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    <description>Extended limitation under the Customs Act cannot be invoked where the Bill of Entry fully disclosed the classification, notification details and IGST rate, and the dispute concerns only the applicable rate on that declared classification. In such circumstances, the issue is treated as one of interpretation rather than suppression or wilful misstatement. The demand was also revenue neutral because IGST paid on import was available as input tax credit under the CGST Act and the goods were subsequently sold on payment of GST. On those facts, the customs demand was held barred by limitation and the extended period was found inapplicable.</description>
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