Extended limitation period for demand failed where refund orders had attained finality after verification of claims.

Refund claims filed with the required statements under Notification No. 56/2002-CE were verified by jurisdictional officers, and refund orders were issued. Because those refund orders were not challenged by the Revenue and had attained finality, the text states that invoking the extended period for issuing the show cause notice was not in accordance with law. On that basis, the demand was treated as time-barred and the stay petition was allowed unconditionally.

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Issues: Whether the demand was barred by limitation in view of the show cause notice having been issued by invoking the extended period.

Analysis: The appellant had filed refund claims along with the required statements under Notification No. 56/2002-CE, the claims were verified by the jurisdictional officers, and refund orders were issued. Those refund orders were not challenged by the Revenue and had attained finality. In these circumstances, invocation of the longer period for issuance of the show cause notice was not in accordance with law.

Conclusion: The demand was held to be time-barred and the stay petition was allowed unconditionally.

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