https://www.taxtmi.com/caselaws?id=756031 Extended limitation for differential duty was held unsustainable in a revenue-neutral dispute where the assessee had paid duty during the disputed period and the Department did not establish positive suppression of facts. The Tribunal noted that the assessee consistently maintained that testing, repacking, palletization and shrink-wrapping were performed at the other appellant's premises, and the Department did not inspect or verify those assertions. On that factual basis, the dispute was treated as revenue-neutral, the extended period could not be invoked, the duty demand failed on limitation, and the connected penalty could not survive. en-us Mon, 22 Jul 2024 00:00:00 +0530 Fri, 26 Jul 2024 09:06:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=756031 Extended limitation for differential duty was held unsustainable in a revenue-neutral dispute where the assessee had paid duty during the disputed period and the Department did not establish positive suppression of facts. The Tribunal noted that the assessee consistently maintained that testing, repacking, palletization and shrink-wrapping were performed at the other appellant's premises, and the Department did not inspect or verify those assertions. On that factual basis, the dispute was treated as revenue-neutral, the extended period could not be invoked, the duty demand failed on limitation, and the connected penalty could not survive. Case-Laws Central Excise Mon, 22 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=756031