2023 (7) TMI 319 - CESTAT KOLKATA

Time Limitation - SCN issued by change of opinion beyond five years - HELD THAT:- The Show Cause Notice has been clearly issued after more than five years from the material date i.e. 12 November 2014 when the Bill of Entry was filed and assessed. Further the Appellant had complied with the requirements of the Project Imports Regulations and completed the documentation. It is further found that the Show Cause Notice has been issued by way of change of opinion beyond the period of five years. Accordingly, the Show Cause Notice is hit by limitation.

Appeal allowed.