Customs Import Dispute: Extended Limitation Period Rejected Due to Procedural Irregularities in Assessment Process

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....CESTAT adjudicated a customs dispute involving invocation of extended limitation period under section 28(1) of Customs Act, 1962. The tribunal examined the procedural validity of a show cause notice issued by revenue authorities regarding thirteen import entries. After analyzing the import documentation and assessment process, the tribunal upheld the Commissioner (Appeals) findings that extended limitation period could not be arbitrarily invoked. The appellant's genuine belief in claiming exemption notification and the fact that goods were examined and cleared during original assessment were critical considerations. Relying on precedential jurisprudence, the tribunal ultimately dismissed the appeal, confirming that revenue authorities cannot retrospectively challenge already assessed and cleared import entries without substantive procedural justification.....