Extended limitation for Cenvat credit denial failed where regular returns were filed and no Revenue objection was shown.

Extended period of limitation could not be invoked to sustain a demand denying Cenvat credit where the assessee had filed regular ER-1 returns and the record showed no objection from the Revenue during the relevant period. The dispute was examined in light of earlier decisions recognising credit on steel items used for fabrication of supporting structures, but the determinative point was limitation. As no suppression or other basis for extended limitation was established, the demand was set aside and the Revenue's appeal was dismissed.

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Issues: Whether the demand for denial of Cenvat credit could be sustained by invoking the extended period of limitation.

Analysis: The respondent had filed regular ER-1 returns, and the record did not show any objection from the Revenue during the relevant period. In view of the earlier decisions supporting credit on steel items used for fabrication of supporting structures, the challenge was examined only on limitation. The invocation of the extended period was found unsustainable.

Conclusion: The demand was rightly set aside on limitation and the Revenue's appeal was dismissed.

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