Appellant Must Pay Duty on Excess Steel Grits and Saw Blades; Time-Barred Argument Rejected per Section 28.

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....SION - Benefit of exemption - Whether the appellant is liable to pay duty on the steel grits and saw blades consumed in excess of the SION? - There are no force in the submissions made by learned counsel for the appellant that the demand is time barred because the course of action arose only after the appellant completed its export and the value of such exports was known. The appellant should have, on own its own, paid the duty in fulfilment of its obligation under the bond or under undertaking but has failed to do so and, therefore, the show cause notice was issued in terms of section 28 read with the bond and legal undertaking - AT....