https://www.taxtmi.com/caselaws?id=784756 The dominant issue was whether the extended limitation under s. 11A could be questioned for the first time in appeal on the basis that the Department had prior knowledge of the assessee's activities. The HC held that while limitation can be raised at any stage as a pure question of law, it becomes a mixed question of law and fact where departmental knowledge is asserted, and it can be examined only if the necessary foundational facts are on record. As the record showed only an exemption form filed by one unit and no material establishing the other unit's prior existence or departmental awareness, the plea lacked factual basis; the Tribunal's rejection of the new limitation plea was upheld and the petition was dismissed. en-us Fri, 02 Jan 2026 00:00:00 +0530 Mon, 12 Jan 2026 09:31:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784756 The dominant issue was whether the extended limitation under s. 11A could be questioned for the first time in appeal on the basis that the Department had prior knowledge of the assessee's activities. The HC held that while limitation can be raised at any stage as a pure question of law, it becomes a mixed question of law and fact where departmental knowledge is asserted, and it can be examined only if the necessary foundational facts are on record. As the record showed only an exemption form filed by one unit and no material establishing the other unit's prior existence or departmental awareness, the plea lacked factual basis; the Tribunal's rejection of the new limitation plea was upheld and the petition was dismissed. Case-Laws Central Excise Fri, 02 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784756