Estoppel by recorded submission bars a later limitation objection to consideration of special rate of value addition.

The High Court treated the respondents' earlier recorded submission as binding and held that they could not later resile from it by invoking limitation under Notification No. 30/2008-C.E. The submission had been understood to mean that the petitioner's request for special rate of value addition would be examined on merits and that the account would be settled accordingly. Because the objection that the application was time-barred was not raised when that position was recorded, and the petitioner acted on that understanding, the respondents were estopped from reopening the issue. They remained bound to consider the request in accordance with law.

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Issues: Whether the respondents were bound by their earlier recorded submission to consider the petitioner's application for special rate of value addition on merits and were precluded from raising the objection that the application was time-barred under Notification No. 30/2008-C.E. dated 10.06.2008.

Analysis: The earlier order between the parties recorded a statement on behalf of the respondents that the petitioner's account would be settled with regard to the special rate of value addition and that the amount would be adjusted against the demand notice. That statement was accepted and the petitioner's grievance was treated as redressed. In the present proceeding, the respondents sought to avoid that commitment by contending that the application for special rate was made beyond the time prescribed under the notification. The Court held that this objection could not be reopened because the respondents had not raised it when the earlier submission was recorded, the submission was understood to mean that the application would be examined on merits, and the petitioner had acted on that understanding.

Conclusion: The respondents were held bound to consider the petitioner's request for special rate of value addition in accordance with law and were estopped from relying on limitation.

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