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EPCG Scheme Dispute: No Provisional Assessment Allowed After Failing to Appeal Bill of Entry Assessment and Duty Recovery Notice.

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....EPCG scheme - additional duty liability which had not been disclosed in the B/E - the impugned show-cause notice is about the recovery of duty foregone in terms of the conditions of the Notification. The appellants having not appealed against the assessment of the Bill of Entry and having not requested for provisional assessment, cannot demand the same while replying to the show-cause notice.....