https://www.taxtmi.com/caselaws?id=44870 Limitation under Section 11A of the Central Excise Act was not extended because the Delhi High Court's interim order only restrained operation of a circular and did not stay service of notice; the exception to limitation was held to require strict construction, so Revenue could not rely on that order. The assessment was also not provisional, because provisional assessment required a specific statutory order and procedure, which were absent; a mere departmental assumption that the matter was sub judice was insufficient, and a new self-assessment theory was not accepted. The demand was therefore time-barred, and the assessee succeeded. en-us Wed, 04 Mar 1998 00:00:00 +0530 Tue, 06 Jan 2026 15:10:21 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=44870 Limitation under Section 11A of the Central Excise Act was not extended because the Delhi High Court's interim order only restrained operation of a circular and did not stay service of notice; the exception to limitation was held to require strict construction, so Revenue could not rely on that order. The assessment was also not provisional, because provisional assessment required a specific statutory order and procedure, which were absent; a mere departmental assumption that the matter was sub judice was insufficient, and a new self-assessment theory was not accepted. The demand was therefore time-barred, and the assessee succeeded. Case-Laws Central Excise Wed, 04 Mar 1998 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=44870