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of The SC held that the price was not the sole consideration for sale under the MOU between OMCs for ensuring uninterrupted supply of petroleum products across India. The revenue failed to record detailed reasons for invoking extended period of limitation under proviso to Section 11A(1) of CEA 1944. No allegation of fraud, collusion or wilful mis-statement was made to levy penalty u/s 11AC. The appeal by the assessee was allowed.
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