Limitation for excise demand runs from the PLA credit date, making a later show-cause notice time-barred and unsustainable.

For limitation purposes, the relevant date was the date on which credit was taken in the Personal Ledger Account, and a notice issued beyond the prescribed period from that date was barred by time. Applying that principle, the notice issued in this matter was held to be beyond limitation because the credit had been taken earlier, so the demand based on the notice could not be sustained and the duty demand was annulled.

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Issues: Whether the show-cause notice was barred by limitation and the demand based thereon was liable to be set aside.

Analysis: The evidence placed on record showed that the relevant credit in the Personal Ledger Account was taken on 22-11-1972. In similar cases, the time limit had been held to run from the date of credit. On that basis, the notice issued on 22-2-1977 was beyond time.

Conclusion: The show-cause notice was time-barred and the demand could not be sustained.

Final Conclusion: The appeal succeeded and the duty demand was annulled on limitation.

Ratio Decidendi: For limitation purposes, the relevant date was the date on which credit was taken in the Personal Ledger Account, and a notice issued beyond the prescribed period from that date was barred by time.

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