Extended Period Not Invokable: CESTAT Rules Constitutional Validity of Renting of Immovable Property Levy Still Pending Before SC

The CESTAT held that an extended period for raising demands under customs duty cannot be invoked in the case of a levy on renting of immovable property because the constitutional validity of such levy is still sub-judice before the Supreme Court. The tribunal declined to open re-assessment or extended demand, emphasizing respect for ongoing judicial scrutiny and protecting taxpayers from retroactive recovery until constitutionality is settled.