Subsequent Notice under Section 28(4) of Customs Act cannot supplement prior notice Under Section 28(1): Delhi High Court
Section 28 of Customs Act, by its very nature posits, in each set of facts and circumstances, the issuance of a SCN either under Section 28(1) or under Section 28(4) of the Act and not under both. Under the circumstances, we are unable to agree that the impugned SCN under section 28(4) of the Act post the issuance of the SCN under Section 28(1) could be termed a “Supplementary Notice”.