Extended limitation for wrongly exempted special additional duty sustained, while related interest and penalty were set aside.

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....Extended limitation for recovering wrongly exempted Special Additional Duty was sustained where, following amendment of the relevant Schedule, the exemption was unavailable and RMS-facilitated imports were cleared on the importer's declaration. The Special Additional Duty demand and its appropriation consequently remained valid. Interest under Section 28AA and penalty under Section 114A on the confirmed duty demand were unsustainable under affirmed precedent and subsequent consistent Tribunal decisions, and were set aside. The modified order retained duty recovery while removing interest and penalty, with consequential relief in accordance with law.....