The Court: Learned counsel appearing for the appellant suggests the
following substantial questions of law by filing the appeal under Section 130 of
the Customs Act, 1962.
“A. Whether the respondent is liable to pay the Safeguard Duty
on the imports of “Solar Photovoltaic Cells” falling under
Customs Tariff Heading 85414011, from Taiwan ?
B. Whether the revenue is correct and justified invoking
Section 28 of the Customs Act, 1962, for recovery of short-
levied duty without challenging the initial assessment/re-
assessment by way of appeal under Section 128 of the
Customs Act, 1962 ?
