I think everybody would say, okay, from the date of the decision of the binational panel or the WTO, you cannot go back and ask for reliquidation
of duties that were paid that have already been liquidated.
sections] 1514 liquidation does not allow subsequent reliquidation
The reliquidation provisions are incorporated into the Treasury Regulations by reference:
The Treasury Regulations clearly contemplate that a taxpayer will obtain a reliquidation of customs duties from the Customs Service before adjusting the value of goods for tax purposes.
by CBP: The TFTE makes a technical correction to the pre-existing law, which allowed CBP to reliquidate an entry within 90 days of the date of notice of liquidation.