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    <description>Denial of Cenvat credit was held to be barred by limitation because the show cause notice relied on the extended period despite the issue being contentious and not free from doubt. The record showed that similarly placed assessees had been granted credit and the Revenue had taken divergent stands, including filing appeals against favourable orders. In these circumstances, invocation of the extended period was not justified, and the credit denial could not be sustained against the assessee.</description>
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      <description>Denial of Cenvat credit was held to be barred by limitation because the show cause notice relied on the extended period despite the issue being contentious and not free from doubt. The record showed that similarly placed assessees had been granted credit and the Revenue had taken divergent stands, including filing appeals against favourable orders. In these circumstances, invocation of the extended period was not justified, and the credit denial could not be sustained against the assessee.</description>
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