https://www.taxtmi.com/caselaws?id=114174 The extended limitation period for central excise duty demands was not available because the statutory prerequisites of fraud, collusion, wilful misstatement, suppression of facts, or intent to evade duty were neither clearly pleaded nor established. The department had knowledge of the relevant facts, yet issued the notices only after a substantial delay, and the dispute arose from a later change of view on classification and exemption applicability rather than any deliberate act by the assessee. Mere disagreement over the nature of inputs or exemption eligibility could not justify invocation of the proviso to the limitation provision, so the demand was time-barred. en-us Fri, 31 Mar 2000 00:00:00 +0530 Fri, 11 May 2012 18:17:04 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=114174 The extended limitation period for central excise duty demands was not available because the statutory prerequisites of fraud, collusion, wilful misstatement, suppression of facts, or intent to evade duty were neither clearly pleaded nor established. The department had knowledge of the relevant facts, yet issued the notices only after a substantial delay, and the dispute arose from a later change of view on classification and exemption applicability rather than any deliberate act by the assessee. Mere disagreement over the nature of inputs or exemption eligibility could not justify invocation of the proviso to the limitation provision, so the demand was time-barred. Case-Laws Central Excise Fri, 31 Mar 2000 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=114174