https://www.taxtmi.com/caselaws?id=43962 The extended limitation under the proviso to Section 11A applies only where the show cause notice specifically alleges fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty. A notice must identify the precise statutory ground relied upon so the assessee can answer that case; a bare allegation of non-declaration of a waste or by-product is insufficient. In the absence of such specific pleadings, the extended period cannot be invoked and the demand based on the impugned notice fails. The Supreme Court's reasoning therefore turned on the adequacy of the notice's averments for limitation purposes. en-us Wed, 18 Jan 1995 00:00:00 +0530 Mon, 06 Jul 2026 11:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=43962 The extended limitation under the proviso to Section 11A applies only where the show cause notice specifically alleges fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade duty. A notice must identify the precise statutory ground relied upon so the assessee can answer that case; a bare allegation of non-declaration of a waste or by-product is insufficient. In the absence of such specific pleadings, the extended period cannot be invoked and the demand based on the impugned notice fails. The Supreme Court's reasoning therefore turned on the adequacy of the notice's averments for limitation purposes. Case-Laws Central Excise Wed, 18 Jan 1995 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=43962