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2022 (8) TMI 726 - HC - CustomsValidity of SCN - corrigendum issued six years later from original SCN - Collection of short levy of Customs Duty - Determination of impugned short levy of duty is saved by limitation under the Act or not - HELD THAT:- Having perused both the original SCN and the ‘corrigendum’ issued six years later on 19th January 2000, this Court has no hesitation in concluding that the so-called corrigendum is in fact a fresh SCN since it materially alters the original SCN both in terms of the demand raised as well as the grounds on which the demand was raised. The question framed for consideration by this Court is answered in the negative i.e. in favour of the Appellant-Assessee and against the Department. The impugned order dated 29th February, 2000 of the Commissioner of Customs and the order dated 9th January, 2002 of the CEGAT are hereby set aside - Petition disposed off.
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