Excise limitation dispute: Tribunal's time-bar finding upheld as the delayed notice defeated most of the demand.

The High Court declined to interfere with the Tribunal's view that the excise demand was time-barred, because the show cause notice was issued much later than the relevant period and only a small portion of the demand could, on the Revenue's own computation, fall within the extended limitation period. The limited period involved and the small amount in dispute also weighed against interference. The reference petition was not entertained, and the Tribunal's order was left undisturbed.

---

---

Issues: Whether the Court should interfere with the Tribunal's order holding the excise demand to be time-barred and decline the Revenue's reference petition.

Analysis: The demand related to a limited period, and the show cause notice was issued much later. The Court found that even on the Revenue's computation, only a small portion of the demand could possibly fall within the extended limitation period. The amount involved was also small, which weighed against interference with the Tribunal's view that the demand was beyond limitation.

Conclusion: The petition was not entertained and the Tribunal's order was left undisturbed, with the result that the Revenue failed.

---