https://www.taxtmi.com/caselaws?id=47436 SC held that the Revenue was entitled to invoke the extended limitation under Section 11A of the Central Excise Act. The court observed that affixing a foreign label alone does not automatically forfeit benefit of the relevant notification and that mere non-declaration is not per se wilful mis-declaration or suppression; there must be a positive act. Where all facts were before the Department and the party genuinely believed the label did not affect entitlement, lack of declaration is not wilful. Nevertheless, if the Department considered the benefit lost, it had to challenge that immediately; decision affirmed for the Revenue. en-us Thu, 15 Sep 2005 00:00:00 +0530 Sat, 20 Sep 2025 12:31:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=47436 SC held that the Revenue was entitled to invoke the extended limitation under Section 11A of the Central Excise Act. The court observed that affixing a foreign label alone does not automatically forfeit benefit of the relevant notification and that mere non-declaration is not per se wilful mis-declaration or suppression; there must be a positive act. Where all facts were before the Department and the party genuinely believed the label did not affect entitlement, lack of declaration is not wilful. Nevertheless, if the Department considered the benefit lost, it had to challenge that immediately; decision affirmed for the Revenue. Case-Laws Central Excise Thu, 15 Sep 2005 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=47436