https://www.taxtmi.com/caselaws?id=799751 Extended limitation for recovery of short-paid IGST under Section 28(4) of the Customs Act requires material establishing collusion, wilful misstatement, or suppression of facts. Where an importer disclosed the goods, tariff classification, and claimed notification benefit in the Bill of Entry accepted by the proper officer, a later departmental disagreement on classification or exemption eligibility, or a bare allegation, does not establish those jurisdictional facts. Recovery must therefore proceed, if at all, within the applicable limitation period. Availability of an appeal under Section 128 does not bar writ jurisdiction where the statutory preconditions for invoking the extended period are absent or proceedings are patently illegal. en-us Thu, 17 Sep 2026 00:00:00 +0530 Sat, 26 Sep 2026 08:31:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799751 Extended limitation for recovery of short-paid IGST under Section 28(4) of the Customs Act requires material establishing collusion, wilful misstatement, or suppression of facts. Where an importer disclosed the goods, tariff classification, and claimed notification benefit in the Bill of Entry accepted by the proper officer, a later departmental disagreement on classification or exemption eligibility, or a bare allegation, does not establish those jurisdictional facts. Recovery must therefore proceed, if at all, within the applicable limitation period. Availability of an appeal under Section 128 does not bar writ jurisdiction where the statutory preconditions for invoking the extended period are absent or proceedings are patently illegal. Case-Laws Customs Thu, 17 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799751