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    <title>2006 (3) TMI 664 - CESTAT, MUMBAI</title>
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    <description>A duty demand was held time-barred because the underlying agreement was entered into when excise duty applied at a specific rate, not on an ad valorem basis. The later shift to an ad valorem regime occurred only in March 1994, so the arrangement could not reasonably be treated as having been structured to evade duty when the value of the goods had no bearing on the duty rate at inception. On that basis, the extended period of limitation was found inapplicable and the entire demand was barred by limitation.</description>
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      <link>https://www.taxtmi.com/caselaws?id=119553</link>
      <description>A duty demand was held time-barred because the underlying agreement was entered into when excise duty applied at a specific rate, not on an ad valorem basis. The later shift to an ad valorem regime occurred only in March 1994, so the arrangement could not reasonably be treated as having been structured to evade duty when the value of the goods had no bearing on the duty rate at inception. On that basis, the extended period of limitation was found inapplicable and the entire demand was barred by limitation.</description>
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