Extended limitation under central excise law was not invocable where facts showed legal confusion and no intent to evade tax.

The Tribunal's refusal to invoke the extended limitation period was upheld because it was based on appreciation of the facts and materials, including confusion in the law at the relevant time and no indication of intent to evade tax. The High Court held that the Revenue's challenge did not raise a substantial question of law under Section 35G of the Central Excise Act, 1944. As the finding on limitation was factual and supported by the record, interference was not warranted and the appeal failed.

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Issues: Whether the Revenue was entitled to contest the Tribunal's finding that the extended period of limitation was not invocable.

Analysis: The Tribunal's conclusion rested on its appreciation of the relevant facts and materials, including the prevailing confusion in law at the relevant time and the absence of any intention to evade payment of tax. The challenge did not disclose a substantial question of law warranting interference under Section 35G of the Central Excise Act, 1944.

Conclusion: The finding against invocation of the extended period of limitation was upheld and the appeal failed.

Final Conclusion: The Revenue's appeal was dismissed, leaving the Tribunal's decision undisturbed.

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