Customs Authority's Late Notice Overturned Due to Appellant's Compliance with Documentation and Lack of Retroactive Checks.

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....Benefit of exemption - At the time of filing the Bill of Entry the appellant have to submit the documents including the country of origin certificate which the appellant have scrupulously complied. If there is doubt in the mind of customs they could have issued show cause notice within the normal period of limitation, as per proviso to Section 28 (4) of Customs Act. However, in the present case the show cause notice was issued beyond the normal period of limitation. - Moreover, on the merit also there is no strict compliance of retroactive check and conclusion thereof - Demand set aside - AT....