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    <title>2026 (4) TMI 1521 - CESTAT AHMEDABAD</title>
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    <description>Declared transaction value was accepted where the alleged undervaluation was supported only by a mobile-phone note and contemporaneous import data that were not shown to be reliable or sufficiently comparable. The note was treated as inadmissible or untrustworthy because its contents did not match the consignments and the requirements for electronic records were not established, while the cited imports differed materially in grade, thickness, width, and commercial characteristics. The extended limitation period was also unavailable because the notice relied on documents already furnished at import and did not establish suppression, collusion, or wilful misdeclaration. Consequential confiscation, duty, interest, and penalty could not be sustained.</description>
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