Show-Cause Notice Quashed for Lack of Jurisdiction Under Section 28(1) Without Allegations of Fraud

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....The HC held that the respondent authority lacked jurisdiction to issue the impugned show-cause notice (SCN) by invoking the extended limitation period under Section 28(1) of the Act, as there was no allegation of collusion, willful mis-statement, or suppression of facts. On merits, the petitioners, who purchased DEPB Licences from the open market for import without duty payment, were found not liable for the demand below the threshold limit. Subsequent developments and the pendency of related proceedings further undermined the SCN's validity. Consequently, the HC quashed and set aside the SCN dated 27.8.2002 against the petitioners, allowing the appeal.....