RBD Palm Stearin Misclassification: No Fraud or Misstatement, No Extended Limitation Period for Show Cause Notice.

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....Classification of goods - RBD Palm Stearin - Making a wrong claim of classification, per se, is neither fraud nor collusion nor wilful misstatement nor suppression of any facts. It is just a wrong claim. If the claim is wrong in the ER-1 returns, it was open for the revenue to have raised demand by issuing a show cause notice immediately. - there is no ground for invoking extended period of limitation - AT....