https://www.taxtmi.com/caselaws?id=89006 The longer period under Rule 56A of the Central Excise Rules, 1944 was unavailable because the show cause notice alleged only "mis-declared" goods and did not allege wilful misstatement, collusion, or suppression of facts in the statutory terms. The Tribunal read the proviso as requiring a wilful element in any misstatement allegation and found the notice materially different from that formulation. On that basis, the Collector's view that the extended period could not be invoked was upheld, and the rectification application failed. en-us Fri, 20 Mar 1998 00:00:00 +0530 Thu, 22 Sep 2011 17:44:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=89006 The longer period under Rule 56A of the Central Excise Rules, 1944 was unavailable because the show cause notice alleged only "mis-declared" goods and did not allege wilful misstatement, collusion, or suppression of facts in the statutory terms. The Tribunal read the proviso as requiring a wilful element in any misstatement allegation and found the notice materially different from that formulation. On that basis, the Collector's view that the extended period could not be invoked was upheld, and the rectification application failed. Case-Laws Central Excise Fri, 20 Mar 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=89006