ORAL JUDGMENT

(PER: HON'BLE MR. JUSTICE K.V. ARAVIND)

Heard Sri.Akash B. Shetty, learned Standing Counsel for the appellant-Commissioner of Customs and Sri. Ravi Raghavan, learned counsel for the respondents in all the appeals.

2. These appeals have been filed by the Revenue, challenging the common Final Order Nos.20343-20345/2020, dated 20.03.2020, passed by the Customs, Excise and Service Tax Appellate Tribunal, Bengaluru (hereinafter referred to as 'CESTAT'). Customs Appeal No.1/2022 is directed against the Company, whereas CSTA Nos.4/2021 and 2/2022 pertain to the Authorized Signatory and the Head of Regulatory Affairs and Quality Assurance of M/s.3M India Limited.

3. For the sake of convenience, the brief facts stated are with reference to the case of M/s. 3M India Limited.

4. This Court, by order dated 29.06.2022, admitted the appeals on the following substantial questions of law:

"IN CSTA 4/2021

"(1) Whether, on the facts and in the circumstances of the case and law, the Tribunal was justified in holding that the show cause notice dated 30.09.2011 could not have covered the period commencing from October, 2006 to February 2010 being the extended period?

(2) Whether, on the facts a