Advance Authorisation

Whose Delay Is It? Delhi High Court Holds a ₹20 Crore Customs Demand Timely Because the Assessee's Own Writ Stay Suspended the Section 28(9) Clock

GKEM International argued that a ₹20.18 crore customs demand was time-barred because its show cause notice sat in the department's 'Call Book' for years. The Delhi High Court disagreed: the delay was occasioned by the assessee's own writ petition and interim stay, which is exactly the circumstance Section 28(9A) excludes from the limitation clock — and the Call Book entry was merely the administrative record of that fact, not its source.