https://www.taxtmi.com/caselaws?id=459353 The extended limitation period under the proviso to Section 11A of the Central Excises and Salt Act, 1944 could be invoked only on proof of fraud, collusion, willful misstatement, willful suppression of facts, or contravention with intent to evade duty. Although the notice alleged misstatement or suppression, it did not specifically plead willfulness, and the adjudicating authority recorded no factual finding that the assessee had acted willfully. In the absence of that jurisdictional precondition, the extended period was unavailable, and the adjudication order was treated as jurisdictionally flawed. en-us Mon, 18 Mar 2019 00:00:00 +0530 Tue, 10 Dec 2024 19:00:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459353 The extended limitation period under the proviso to Section 11A of the Central Excises and Salt Act, 1944 could be invoked only on proof of fraud, collusion, willful misstatement, willful suppression of facts, or contravention with intent to evade duty. Although the notice alleged misstatement or suppression, it did not specifically plead willfulness, and the adjudicating authority recorded no factual finding that the assessee had acted willfully. In the absence of that jurisdictional precondition, the extended period was unavailable, and the adjudication order was treated as jurisdictionally flawed. Case-Laws Central Excise Mon, 18 Mar 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459353