https://www.taxtmi.com/caselaws?id=794969 Rectification under the Customs Act is confined to errors apparent from the record and cannot be used to reopen a debatable issue or seek a fresh determination. The note explains that, where the adjudicating authority accepts the importer's declared tariff classification, the alleged misdeclaration or misclassification does not survive. As extended limitation requires non-levy or short levy arising from collusion, wilful misstatement, or suppression, its factual foundation is absent in those circumstances. Where the classification dispute is interpretational and the substantive decision eliminates the duty demand, a separate challenge to the extended period becomes academic. The Revenue's rectification application was therefore described as not maintainable. en-us Mon, 13 Jul 2026 00:00:00 +0530 Wed, 15 Jul 2026 08:22:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794969 Rectification under the Customs Act is confined to errors apparent from the record and cannot be used to reopen a debatable issue or seek a fresh determination. The note explains that, where the adjudicating authority accepts the importer's declared tariff classification, the alleged misdeclaration or misclassification does not survive. As extended limitation requires non-levy or short levy arising from collusion, wilful misstatement, or suppression, its factual foundation is absent in those circumstances. Where the classification dispute is interpretational and the substantive decision eliminates the duty demand, a separate challenge to the extended period becomes academic. The Revenue's rectification application was therefore described as not maintainable. Case-Laws Customs Mon, 13 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794969