SSI benefit cannot be denied for a mere approved change of name; extended limitation also failed.

A mere change in the unit's name, after approval by the competent authorities, did not alter the undertaking's identity or status, so SSI benefit could not be denied on that ground. On the admitted facts, no basis existed to justify invocation of the extended period of limitation for the demand. The demand was set aside and the appeal was allowed.

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Issues: (i) Whether SSI benefit could be denied merely because the unit's name was changed after approval by the competent authorities; (ii) Whether the extended period of limitation could be invoked for the demand.

Issue (i): Whether SSI benefit could be denied merely because the unit's name was changed after approval by the competent authorities.

Analysis: The unit, management and registration remained the same and only the name changed. The approved change of name did not alter the identity or status of the unit. A mere change in nomenclature could not take away an existing benefit otherwise available to the same undertaking.

Conclusion: The denial of SSI benefit on the ground of change of name was not sustainable and the finding was in favour of the assessee.

Issue (ii): Whether the extended period of limitation could be invoked for the demand.

Analysis: On the admitted facts, no basis was made out to justify invocation of the extended period.

Conclusion: Invocation of the extended period was not justified and this issue was also decided in favour of the assessee.

Final Conclusion: The demand was set aside and the appeal was allowed.

Ratio Decidendi: Where the legal identity of the unit remains unchanged and only its name is altered with approval, substantive fiscal benefit cannot be denied on that ground, and the extended period cannot be invoked absent ingredients warranting such action.

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