https://www.taxtmi.com/caselaws?id=89489 A demand or appeal cannot be sustained on a ground wholly different from the one set out in the show cause notice. Here, the notice was limited to PVC waste arising from PVC granules, but the Revenue's review and appeal proceeded on a new basis that the waste arose from manufacture of wires and cables, involving different goods and tariff chapters. Because the Department sought to advance a factual and legal case never put to the assessee in the notice, the proceeding could not be maintained. The Revenue's appeal on the new ground was therefore rejected. en-us Wed, 02 Dec 1998 00:00:00 +0530 Tue, 27 Sep 2011 14:32:23 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=89489 A demand or appeal cannot be sustained on a ground wholly different from the one set out in the show cause notice. Here, the notice was limited to PVC waste arising from PVC granules, but the Revenue's review and appeal proceeded on a new basis that the waste arose from manufacture of wires and cables, involving different goods and tariff chapters. Because the Department sought to advance a factual and legal case never put to the assessee in the notice, the proceeding could not be maintained. The Revenue's appeal on the new ground was therefore rejected. Case-Laws Central Excise Wed, 02 Dec 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=89489