Tariff reclassification burden required article-specific evidence, defeating extended limitation, confiscation, and penalties for imported vehicle parts.

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....Revenue must establish tariff reclassification through evidence of each imported article's objective characteristics, applicable tariff entries, Section Notes and Explanatory Notes; representative sampling, undisclosed website material and unreasoned end-use assertions were insufficient. The proposed reclassification and consequential denial of concessional duty failed. Extended limitation required pleaded and proven collusion, wilful misstatement or suppression; a corrigendum could not add new articles or bills of entry, and charges first introduced through it ran from its date. The extended-period demand was unavailable. Duty determination had to reconcile annexures and appropriate verified payments, so the unreconciled demand failed. Inc.........