Customs duty on conversion from foreign to coastal run held not leviable where imports predated Notification No.12/2012; demand quashed

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....Whether customs duty on conversion from foreign to coastal run is leviable when import occurred before Notification No.12/2012: court held liability arises at the time of first import (date of import controls), and because the relevant imports predated the Notification, no duty was attractable - demand quashed. Whether the impugned letter constituted a valid demand or merely a show-cause notice: court found the enclosed computation and 14-day remittance call rendered it a substantive demand, not a procedural notice, and therefore the communication was invalid - quashed. - HC....