https://www.taxtmi.com/caselaws?id=81082 The extended limitation period under excise law cannot be invoked unless the Department proves suppression of material facts, misstatement, fraud, collusion, or deliberate contravention with intent to evade duty. Mere failure to file a declaration, obtain a central excise licence, or complete procedural formalities does not by itself establish wilful evasion where the unit was registered, held the relevant board licences, and operated on a relatively small scale under a plausible belief that duty was not payable. On those facts, the demand was time-barred and the penalty was not sustainable. en-us Wed, 13 Feb 1991 00:00:00 +0530 Wed, 22 Jun 2011 13:12:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=81082 The extended limitation period under excise law cannot be invoked unless the Department proves suppression of material facts, misstatement, fraud, collusion, or deliberate contravention with intent to evade duty. Mere failure to file a declaration, obtain a central excise licence, or complete procedural formalities does not by itself establish wilful evasion where the unit was registered, held the relevant board licences, and operated on a relatively small scale under a plausible belief that duty was not payable. On those facts, the demand was time-barred and the penalty was not sustainable. Case-Laws Central Excise Wed, 13 Feb 1991 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=81082