Extended limitation rejected; classification of cold rolled stainless steel strips remanded for fresh review of duty benefits, penalties

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....CESTAT held that classification of the imported cold rolled stainless steel strips requires detailed factual examination of manufacturing processes, grade and composition, and may warrant consideration of tariff headings beyond those proposed by either side. As the SCNs were based on information supplied by the importer and the issue is legally and factually contentious, the Tribunal disallowed invocation of the extended period of limitation; any differential duty and interest must be computed only for the normal period. The matter was remanded to the adjudicating authority to re-determine tariff classification, examine discrepancies between commercial invoices and certificates of origin vis-à-vis concessional duty claims, and reconsider penalties on directors and other individuals.....