Petition dismissed; Rule 25 SEZ Rules applies, refund demand for customs duty upheld due to unused imported goods

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....The HC dismissed the petition and upheld the Specified Officer's demand for refund of customs duty equivalent to benefits claimed under Rule 25 of SEZ Rules, holding that the petitioner failed to utilize imported goods within the stipulated validity/extended period. The court found Rule 25 applicable (not Rule 27(9)), and that prior extension grants and a pending further extension application did not estop the authority or create a legitimate expectation to defeat statutory liability; earlier administrative decision prevailed. The HC declined to exercise writ jurisdiction under Art. 226, concluding no grounds existed to interfere with the duty demand and enforcement action.....