In case of doubt on dutiability of goods, extended period of limitation cannot be invoked

The Tribunal had also, considering the fact that when there was a scope for doubt whether the goods were dutiable or not, refused to apply extended period of limitation. The Tribunal relied on the judgments of the Supreme Court in Camphor Drugs and Laminates , Collector v. Himalayan Co-op. Milk Product Union Ltd. , Collector v. Malleable Iron & Steel Castings Co. (P) Ltd. , H.M.M. Ltd. v. Collector , Padmini Products v. Collector , Pushpam Pharmaceuticals Company v. Collector and Tamil Nadu Housing Board v. Collector , and refused to set aside the Order-in-

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