Provisionally Assessed Bills of Entry Must Be Finalized Within 5 Years; No Pending Petition or Stay Justifies Delay.

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....Finalization of provisionally assessed Bills of Entry, beyond a period of five years - neither there was any petition of petitioners pending before Competent Court nor was any stay of any court, thus there was no reason to withhold framing of final assessment. - final assessment u/s 18 cannot be made after the expiry of five years from the date of bill of entry.....