Importer Transparency Prevents Five-Year Reopening u/s 28(4) Due to No Intentional Misstatement of Facts.

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....Extended period of limitation - It is pertinent to note that the importer had asked for a first check and had shown the cameras and the cameras were offered on 20.3.2012 along with Bill of Entry and literature detailing specifications of models. - It is difficult in such circumstances to infer that there was any wilful misstatement of facts. In these circumstances, it must, therefore, follow that the extended period of limitation of five years was not available to any authority to re-open under Section 28(4). - SC....