Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classification.

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....Dispute concerns classification of imported salvaged/broken shaft pieces and whether re-classification and recovery of differential duty was time-barred and justified by alleged suppression. The commercial invoice and SAFTA certificate declared the goods as parts of ship under CTH 7326 9090, and the goods, after salvage, lost original identity and assumed character of iron and steel ship parts, meriting classification under that heading; consequently the proposed change lacked sustainable reasons. There was no evidence of concealment warranting extended limitation; matter was revenue neutral. The impugned reassessment was set aside and the appeal allowed.....