Extended limitation cannot apply absent suppression; disclosed imports and revenue neutrality made the IGST demand time-barred.

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....Extended period of limitation under customs and IGST law is available only where suppression, wilful misstatement, collusion or fraud is established. Here, the Tribunal found that the Bill of Entry disclosed the classification, notification number, serial number and applied IGST rate, and treated the dispute as one of interpretation over the applicable IGST rate rather than concealment. It also held the matter revenue neutral because the importer could avail input tax credit of any additional IGST paid. The demand was therefore held time-barred and unsustainable, without examining the merits of the IGST rate.....