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Section 28 Recovery: unpaid anti-dumping duty may be demanded without overturning self-assessment; IGST and contemporaneous penalty limits apply.

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....Section 28 permits recovery of unpaid or short-paid anti-dumping duty through a demand notice without first challenging the importer's self-assessment. This recovery mechanism is distinct from refund proceedings, where an unmodified self-assessment may restrict relief. Anti-dumping duty imposed under the Customs Tariff Act is treated as customs duty for calculating IGST on imported goods; IGST therefore applies to the aggregate value including such duty. The maximum penalty for non-payment is governed by the statutory ceiling applicable on the date of import, and a subsequently enhanced ceiling cannot apply retrospectively.....