https://www.taxtmi.com/caselaws?id=84447 A corporate arrangement set up as a separate unit was treated as a mere facade for excise purposes, because the facts showed common control, no genuine transfer of assets and liabilities, and a device to secure separate small-scale exemption; the units were therefore clubbed and exemption under Notification No. 77/85-C.E. was denied. The duty demand for the relevant period was held time-barred because departmental knowledge, prior filings, and earlier litigation meant wilful suppression or misstatement was not established, so the extended limitation period could not apply. Penalty was nevertheless sustained on the footing that the arrangement amounted to deliberate evasion of duty. en-us Thu, 07 Sep 1995 00:00:00 +0530 Fri, 22 Jul 2011 10:44:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=84447 A corporate arrangement set up as a separate unit was treated as a mere facade for excise purposes, because the facts showed common control, no genuine transfer of assets and liabilities, and a device to secure separate small-scale exemption; the units were therefore clubbed and exemption under Notification No. 77/85-C.E. was denied. The duty demand for the relevant period was held time-barred because departmental knowledge, prior filings, and earlier litigation meant wilful suppression or misstatement was not established, so the extended limitation period could not apply. Penalty was nevertheless sustained on the footing that the arrangement amounted to deliberate evasion of duty. Case-Laws Central Excise Thu, 07 Sep 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=84447