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CESTAT allowed the appeal, finding that the appellant acted in good faith by disclosing all relevant facts in coal extraction returns. The tribunal held that the extended period of limitation under Section 11A(4) of the Central Excise Act was improperly invoked, as the appellant did not intentionally suppress information or evade duty. The demand for the period March 2011 to February 2015 was set aside, with the tribunal emphasizing that a bona fide interpretation of legal provisions does not constitute deliberate suppression of facts, consistent with Supreme Court precedent on self-assessment principles.
CESTAT allowed the appeal, finding that the appellant acted in good faith by disclosing all relevant facts in coal extraction returns. The tribunal held that the extended period of limitation under Section 11A(4) of the Central Excise Act was improperly invoked, as the appellant did not intentionally suppress information or evade duty. The demand for the period March 2011 to February 2015 was set aside, with the tribunal emphasizing that a bona fide interpretation of legal provisions does not constitute deliberate suppression of facts, consistent with Supreme Court precedent on self-assessment principles.
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