https://www.taxtmi.com/caselaws?id=443095 Extended limitation under section 11A of the Central Excise Act could not be invoked without proof of suppression of facts or wilful misstatement with intent to evade duty. Mere disagreement with audit objections did not establish suppression, especially where the return format did not require the disputed particulars and the statutory scrutiny mechanism had the duty to examine returns and call for records. Revenue neutrality was relevant to intention: if duty payment would have been available as credit to the buyer or related unit, the element of intent to evade was absent. The demand was therefore time-barred, and the consequential interest and penalty could not be sustained. en-us Fri, 15 Sep 2023 00:00:00 +0530 Sat, 16 Sep 2023 08:45:28 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=443095 Extended limitation under section 11A of the Central Excise Act could not be invoked without proof of suppression of facts or wilful misstatement with intent to evade duty. Mere disagreement with audit objections did not establish suppression, especially where the return format did not require the disputed particulars and the statutory scrutiny mechanism had the duty to examine returns and call for records. Revenue neutrality was relevant to intention: if duty payment would have been available as credit to the buyer or related unit, the element of intent to evade was absent. The demand was therefore time-barred, and the consequential interest and penalty could not be sustained. Case-Laws Central Excise Fri, 15 Sep 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=443095