https://www.taxtmi.com/caselaws?id=783921 Binding CBIC circulars require pre-consultation before issuing show cause notices or passing orders-in-original under central excise and allied tax laws, and that step is not a mere formality. The Department cannot omit pre-consultation simply because it proposes to invoke extended limitation, as allegations of fraud, suppression, wilful misstatement, or intent to evade duty remain disputed factual matters requiring evidence. The pre-consultative mechanism is part of trade facilitation and alternative dispute resolution, subject only to recognised exceptions in the circulars. Without compliance, the impugned notices and assessment orders could not be sustained. en-us Mon, 15 Dec 2025 00:00:00 +0530 Fri, 26 Dec 2025 07:18:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783921 Binding CBIC circulars require pre-consultation before issuing show cause notices or passing orders-in-original under central excise and allied tax laws, and that step is not a mere formality. The Department cannot omit pre-consultation simply because it proposes to invoke extended limitation, as allegations of fraud, suppression, wilful misstatement, or intent to evade duty remain disputed factual matters requiring evidence. The pre-consultative mechanism is part of trade facilitation and alternative dispute resolution, subject only to recognised exceptions in the circulars. Without compliance, the impugned notices and assessment orders could not be sustained. Case-Laws Central Excise Mon, 15 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783921