https://www.taxtmi.com/caselaws?id=125722 Duty demand for 1993-94 was held time-barred because the show cause notice was issued only in January 1997 and the Revenue could not rely on the extended limitation period without proof of suppression of facts with intent to evade duty. The Tribunal noted that the legal position on whether fabrication of structural items amounted to manufacture had been viewed differently at the relevant time, so the assessee could not be attributed with the requisite mens rea. The substantive manufacture issue was left open, as the matter was resolved on limitation alone. en-us Fri, 12 Dec 2008 00:00:00 +0530 Mon, 29 Oct 2012 15:42:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=125722 Duty demand for 1993-94 was held time-barred because the show cause notice was issued only in January 1997 and the Revenue could not rely on the extended limitation period without proof of suppression of facts with intent to evade duty. The Tribunal noted that the legal position on whether fabrication of structural items amounted to manufacture had been viewed differently at the relevant time, so the assessee could not be attributed with the requisite mens rea. The substantive manufacture issue was left open, as the matter was resolved on limitation alone. Case-Laws Central Excise Fri, 12 Dec 2008 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=125722