Circular No. 312/28/97-CX It has been noticed that quite a lot of unnecessary litigation and avoidable work is created by indiscriminate issue of show cause notices/ less charge demands invoking the proviso to Section 11-A of CESA or to Section 28 of the Customs Atc, etc. even when there is no fraud or misdeclaration, etc., for example, where there has been an established practice well within the knowledge of one Department.