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Customs House Agent Penalized u/s 112(a) for Alleged Abetment; Examining Sections 28(2) & 28(4) for Fact Suppression.

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....Validity of SCN - Levy of Penalty u/s 112(a) of Customs Act on CHA - abetment of offence committed by the importer as against which the petitioner - scope of Sections 28(2) and 28(4) of the Customs Act, 1962 - suppression of facts or not - extended period of limitation - the benefit u/s 28(2) is available only in the case of a β€˜regular’ assessment contemplated made u/s 28(1). This is made clear by the explicit exclusion in Section 28(1) of cases of collusion, wilful mis-statement or suppression of facts for the initiation of which revenue has the benefit of an extended limitation of five years. - HC....