https://www.taxtmi.com/caselaws?id=81699 In a physically controlled excise regime, clubbing of clearances and denial of exemption cannot rest on suspicion, common branding or shared trading channels; the Department must prove centralised manufacture with reliable evidence. Separate licences, separate statutory records, physical control and regular inspections weighed against the allegation that seven match units were only fronts for one manufacturer, so the clearances could not be clubbed and the exemption claim stood. The extended limitation period also required proof of suppression, but departmental knowledge, repeated visits and the first inspection facts negatived any hidden activity. As a result, the demand and penalty could not be sustained on clubbing or limitation grounds. en-us Mon, 09 Mar 1992 00:00:00 +0530 Tue, 28 Jun 2011 12:51:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=81699 In a physically controlled excise regime, clubbing of clearances and denial of exemption cannot rest on suspicion, common branding or shared trading channels; the Department must prove centralised manufacture with reliable evidence. Separate licences, separate statutory records, physical control and regular inspections weighed against the allegation that seven match units were only fronts for one manufacturer, so the clearances could not be clubbed and the exemption claim stood. The extended limitation period also required proof of suppression, but departmental knowledge, repeated visits and the first inspection facts negatived any hidden activity. As a result, the demand and penalty could not be sustained on clubbing or limitation grounds. Case-Laws Central Excise Mon, 09 Mar 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=81699