https://www.taxtmi.com/caselaws?id=790820 Limitation governed the dispute, and the classification issue was not examined. A show cause notice issued about four years after the initial clearance was found unsustainable because the appellant had consistently classified prior and subsequent imports in the same manner, supporting a bona fide belief. The absence of penalty under Section 114AA of the Customs Act, 1962 did not itself establish that there was no suppression, but the record still did not justify use of the extended period. The principle applied was that the extended period under Section 28(1) is available only where suppression or wilful misstatement is established, so the demand was held time-barred. en-us Wed, 25 Mar 2026 00:00:00 +0530 Fri, 01 May 2026 10:14:38 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790820 Limitation governed the dispute, and the classification issue was not examined. A show cause notice issued about four years after the initial clearance was found unsustainable because the appellant had consistently classified prior and subsequent imports in the same manner, supporting a bona fide belief. The absence of penalty under Section 114AA of the Customs Act, 1962 did not itself establish that there was no suppression, but the record still did not justify use of the extended period. The principle applied was that the extended period under Section 28(1) is available only where suppression or wilful misstatement is established, so the demand was held time-barred. Case-Laws Customs Wed, 25 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790820