TMI Blog2025 (2) TMI 1121X X X X Extracts X X X X X X X X Extracts X X X X ..... ELD THAT:- From the documents placed on record, it is found that the appellant, upon import, had filed various Bills of Entry right from 09.04.2003 and the last presentation of such Bills of Entry was dated 04.06.2003 though it is undisputed that the imports were made against different DEPB licenses. The date of Show Cause Notice, as noted supra, is 19.12.2005 which is clearly beyond two years, mo ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... horized Representative for the Respondent ORDER By this appeal, the appellant assessee is, inter alia, challenging the impugned order of the Commissioner (Appeals) dated 04.04.2013. When the case was taken up for hearing, Smt. Anandalakshmi Ganeshram, ld. Assistant Commissioner would submit, at the outset, that the issue involved in this case being importation of melting scrap without proper ins ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ized the DEPB licenses issued in the year 2002, the Bills of Entry were filed between April to June 2003 for which the SCN dt. 19.12.2005 is issued, which is clearly beyond the normal period. He would also contend that the authorities below have confirmed the invocation of extended period of limitation, blindly without any justification. 3. Per contra, Smt. Anandalakshmi Ganeshram, Ld. Assistant ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Entry was dated 04.06.2003 though it is undisputed that the imports were made against different DEPB licenses. The date of Show Cause Notice, as noted supra, is 19.12.2005 which is clearly beyond two years, moreover in the SCN strangely, the Authority has only proposed to raise the demand under provisions of Section 28 (1) ibid. Hence, the findings of the Original Authority in the Order--in--O ..... X X X X Extracts X X X X X X X X Extracts X X X X
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