Import classification dispute over linear accelerator held time-barred under limitation; SCN set aside and appeal allowed

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....SCN issued after provisional assessment for imported medical equipment was held time-barred under limitation rules; the Tribunal treated extended period considerations under Section 28(4) as inapplicable and relied on coordinate precedents finding similar clearance-stage examinations beyond the normal period. The Tribunal noted a bona fide classification dispute over tariff heading, observed that burden of proof lay with the Revenue on mis-declaration or suppression, and therefore struck down the SCN. Consequence: confiscation, penalties and interest claims were not adjudicated on merits; the appeal was allowed and the impugned order set aside with consequential relief to the appellant.....