2023 (4) TMI 1484

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....NTH,J. Mr. Rajendran Raghavan, learned Senior Standing Counsel accepts notice for the respondents and seeks some time to obtain instructions and file a counter. 2. The time scheme for finalisation of assessments as set out under Section 28(9) of the Customs Act, 1962 is as follows: '28. Recovery of duties not levied or not paid or short-levied or short-paid] or erroneously refun....

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....one year: Provided further that where the proper officer fails to determine within such extended period, such proceeding shall be deemed to have concluded as if no notice had been issued' 3. Thus, in cases where extended limitation has been invoked, the officer has the benefit of one year from date of notice to complete the proceedings. 4. The notice in this case is dated 21.12.2020. The....