Notice after 9 years of Bill of Entry cannot be treated as notice within a reasonable period

Commissioner of Customs Vs Anurag Trading Company (Delhi High Court) It is relevant to note that the period of limitation as provided under Section 28 of the Customs Act is a period of five years from the relevant date. It is, thus, apparent that the learned CESTAT had proceeded on the basis that a reasonable period for taking an action under Section 28B of the Customs Act would also be a period of five years. Thus, even if it is accepted that the limitation period under Section 28 of the Customs Act cannot per se be imputed to any action under Section 28B of the Customs Act, there can be no c...