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Confiscation Unjustified: Department Failed Procedure, No Mis-declaration Found. Burden of Proof Not Met.

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....Rejection of declared value - Confiscation - Since it is apparent that the Department has not followed the statutory procedure nor there was any mis-declaration of quantity as alleged, the mere acceptance of the re-assessed value and payment thereof will not be sufficient to confirm the allegations of under valuation. The burden was still on the Department to prove the allegations levelled. The said burden has not been discharged. - AT....