Ad-interim stay on belated provisional assessment finalization; 12-15 year delay held prima facie unreasonable for importer

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....HC, in a writ petition challenging a SCN seeking finalization of provisional assessments for Bills of Entry dated August 2010 to September 2013, found substantial merit in the importer-petitioner's contentions. Relying on the principle that provisional assessments must be finalized within a reasonable time, approximately five years, the HC held that a delay of 12-15 years is prima facie unreasonable. The Court also accepted that evidence of end-use after 15 years would be impracticable. Holding that a strong prima facie case exists, HC granted ad-interim relief and listed the matter for 8 January 2026.....