Burden of proof in gold seizure and documentary scrutiny led to remand; limitation objection to notice was rejected.

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....For notified goods such as gold, seizure on reasonable belief initially shifts the burden to the person concerned to prove lawful acquisition under Section 123. The appellate authority's absolute release of the seized gold was unsustainable because it accepted books, invoices and GST records without correlating the entries or addressing discrepancies and the admitted fabrication of invoices and stock records. The order was therefore set aside and the matter remanded for fresh examination of the documentary evidence and the Revenue's grounds. The limitation objection to the show-cause notice was rejected, as the notice was covered by the statutory extension under the relaxation law and the objection had not been raised below.....