https://www.taxtmi.com/caselaws?id=794969 Rectification jurisdiction under the Customs Act cannot be used to reopen a debatable issue or obtain a fresh decision on extended limitation. Where the declared tariff classification was accepted, the alleged misdeclaration or misclassification did not survive, removing the factual basis for invoking the extended period based on collusion, wilful misstatement or suppression. As the classification issue was interpretational and the substantive decision eliminated the duty demand, a separate determination on extended limitation was academic. The Revenue's rectification application was therefore not maintainable because no error apparent from the record was established. 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 jurisdiction under the Customs Act cannot be used to reopen a debatable issue or obtain a fresh decision on extended limitation. Where the declared tariff classification was accepted, the alleged misdeclaration or misclassification did not survive, removing the factual basis for invoking the extended period based on collusion, wilful misstatement or suppression. As the classification issue was interpretational and the substantive decision eliminated the duty demand, a separate determination on extended limitation was academic. The Revenue's rectification application was therefore not maintainable because no error apparent from the record was established. Case-Laws Customs Mon, 13 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794969