https://www.taxtmi.com/caselaws?id=81766 Extended limitation under excise law cannot be invoked unless the show cause notice itself alleges fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty; mere reference to excise rules is insufficient, so the demand remained time-barred. A pure question of law that does not require fresh factual enquiry may be raised for the first time in appeal, and appellate consideration of the limitation objection was therefore permissible. Because the dispute was resolved on the notice language and the legal objection was entertainable at the appellate stage, no referable question of law arose and the reference application was dismissed. en-us Fri, 17 Jan 1992 00:00:00 +0530 Tue, 28 Jun 2011 17:07:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=81766 Extended limitation under excise law cannot be invoked unless the show cause notice itself alleges fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty; mere reference to excise rules is insufficient, so the demand remained time-barred. A pure question of law that does not require fresh factual enquiry may be raised for the first time in appeal, and appellate consideration of the limitation objection was therefore permissible. Because the dispute was resolved on the notice language and the legal objection was entertainable at the appellate stage, no referable question of law arose and the reference application was dismissed. Case-Laws Central Excise Fri, 17 Jan 1992 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=81766