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    <title>2019 (3) TMI 775 - CESTAT NEW DELHI</title>
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    <description>The extended period of limitation could not be invoked for the show cause notice on clearance of ready mix concrete because the department had earlier treated the product as exempt or had already taken a view on the same controversy. As later judicial rulings settled the ready mix concrete and concrete mix issue, the subsequent notice was based on a change of opinion rather than fresh material. In the absence of collusion, suppression of facts, or wilful misstatement, the notice invoking the extended period was not maintainable and the matter was decided in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=376754</link>
      <description>The extended period of limitation could not be invoked for the show cause notice on clearance of ready mix concrete because the department had earlier treated the product as exempt or had already taken a view on the same controversy. As later judicial rulings settled the ready mix concrete and concrete mix issue, the subsequent notice was based on a change of opinion rather than fresh material. In the absence of collusion, suppression of facts, or wilful misstatement, the notice invoking the extended period was not maintainable and the matter was decided in favour of the assessee.</description>
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