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The HC dismissed the Revenue's appeal and upheld the CESTAT's finding that the assessee did not willfully suppress material facts to invoke the proviso to s.11A(1) of the Central Excise Act for an extended limitation period. The court concluded that both Revenue and the assessee had knowledge of the draw-warping activities, and the assessee's reliance on a notification did not amount to fraud, misrepresentation or willful concealment. Consequently, the show cause notice issued beyond the normal limitation was time-barred, and the CESTAT correctly set aside demands predicated on the extended period; substantial questions of law were answered for the assessee and against the Revenue.
The HC dismissed the Revenue's appeal and upheld the CESTAT's finding that the assessee did not willfully suppress material facts to invoke the proviso to s.11A(1) of the Central Excise Act for an extended limitation period. The court concluded that both Revenue and the assessee had knowledge of the draw-warping activities, and the assessee's reliance on a notification did not amount to fraud, misrepresentation or willful concealment. Consequently, the show cause notice issued beyond the normal limitation was time-barred, and the CESTAT correctly set aside demands predicated on the extended period; substantial questions of law were answered for the assessee and against the Revenue.
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