https://www.taxtmi.com/caselaws?id=773395 The Tribunal allowed the appellants' challenge to the extended limitation period under Section 11A of the Central Excise Act. Despite the appellants losing on merits regarding duty liability, the Tribunal held that the show cause notice issued beyond the normal six-month period was time-barred. The Tribunal found no "intent to evade" duty, noting that the appellants' failure to obtain a Central Excise license amid conflicting legal interpretations and ongoing litigation constituted a bona fide legal dispute rather than deliberate evasion. The existence of multiple conflicting judicial opinions, including SC precedents in Padmini Products and Baidyanath Ayurved Bhavan, supported that extended limitation could not be invoked where genuine legal uncertainty existed. en-us Fri, 20 Jun 2025 00:00:00 +0530 Mon, 23 Jun 2025 08:42:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=773395 The Tribunal allowed the appellants' challenge to the extended limitation period under Section 11A of the Central Excise Act. Despite the appellants losing on merits regarding duty liability, the Tribunal held that the show cause notice issued beyond the normal six-month period was time-barred. The Tribunal found no "intent to evade" duty, noting that the appellants' failure to obtain a Central Excise license amid conflicting legal interpretations and ongoing litigation constituted a bona fide legal dispute rather than deliberate evasion. The existence of multiple conflicting judicial opinions, including SC precedents in Padmini Products and Baidyanath Ayurved Bhavan, supported that extended limitation could not be invoked where genuine legal uncertainty existed. Case-Laws Central Excise Fri, 20 Jun 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=773395