COMMISSIONER OF CUSTOMS (EXPORT) Vs. RELIANCE INDUSTRIES LIMITED

JUDGEMENT

(1.) On 25th June 2014 this appeal was admitted and the following substantial questions of law were framed :

(2.) On 4th December 2021, the following order came to be passed :

(3.) Ms. Cardozo submitted that where any duty has not been levied or not paid or has been short levied or short paid or erroneously refunded, or any interest payable has not been paid or part paid or erroneously refunded, for any reason other than the reasons of collusion or any willful mis-statement or suppression of facts, the proper officer shall, within the time prescribed from the relevant date, serve notice on the person chargeable with the duty or interest which has not been so levied or paid or which has been short levied or short paid or to whom the refund has erroneously been made, requiring him to show cause why he should not pay the amount specified in the notice.