https://www.taxtmi.com/caselaws?id=78275 The extended limitation period under the proviso to Section 11A(1) of the Customs Act applies only where the Revenue proves fraud, collusion, wilful misstatement, suppression of facts, or intentional contravention to evade duty. Strict construction of the proviso requires more than departmental ignorance or the mere fact that units fell under the same division. The Tribunal's limitation finding was held unsustainable because it did not test the facts against those statutory ingredients, and the matter was remanded for fresh determination on whether the extended period could validly be invoked. en-us Fri, 12 Nov 2010 00:00:00 +0530 Fri, 21 Nov 2025 11:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=78275 The extended limitation period under the proviso to Section 11A(1) of the Customs Act applies only where the Revenue proves fraud, collusion, wilful misstatement, suppression of facts, or intentional contravention to evade duty. Strict construction of the proviso requires more than departmental ignorance or the mere fact that units fell under the same division. The Tribunal's limitation finding was held unsustainable because it did not test the facts against those statutory ingredients, and the matter was remanded for fresh determination on whether the extended period could validly be invoked. Case-Laws Central Excise Fri, 12 Nov 2010 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=78275