https://www.taxtmi.com/caselaws?id=1126 The extended period of limitation under excise law cannot be invoked absent material showing wilful suppression of facts with intent to evade duty. The demand on cigarette samples drawn for quality testing arose from a long-standing bona fide dispute, with earlier conflicting rulings, disclosure by the assessee of its stand, subsequent voluntary payment for the later period, and revised record-keeping. The notice was also based on theoretical estimation rather than undisclosed private records, and the department did not act promptly after the Supreme Court settled the issue. On these facts, the show cause notice was held time-barred and the demand unsustainable, with the appeal succeeding for the assessee. en-us Thu, 20 Jul 2006 00:00:00 +0530 Mon, 14 Apr 2008 11:10:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=1126 The extended period of limitation under excise law cannot be invoked absent material showing wilful suppression of facts with intent to evade duty. The demand on cigarette samples drawn for quality testing arose from a long-standing bona fide dispute, with earlier conflicting rulings, disclosure by the assessee of its stand, subsequent voluntary payment for the later period, and revised record-keeping. The notice was also based on theoretical estimation rather than undisclosed private records, and the department did not act promptly after the Supreme Court settled the issue. On these facts, the show cause notice was held time-barred and the demand unsustainable, with the appeal succeeding for the assessee. Case-Laws Central Excise Thu, 20 Jul 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=1126