K.R.SHRIRAM, AMIT B.BORKAR
Commissioner of Customs (Export) – Appellant
Versus
Reliance Industries Limited – Respondent
JUDGMENT :
K.R. SHRIRAM, J.
1. On 25th June 2014 this appeal was admitted and the following substantial questions of law were framed :
(ii) Whether in the facts and circumstances of the case and in law the Tribunal is justified in holding that the policy will prevail over the customs notification when the Ministry of Finance, Govt. of India has every authority to regulate the customs duty benefit?
(iii) Whether in the facts and circumstances of the case and in law the Tribunal is justified in holding that the extended period of limitation is not available despite the fact that the benefit of notification was availed by willfully mis-declaring the goods?”
2. On 4th December 2021, the following order came to be passed :
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