https://www.taxtmi.com/caselaws?id=786583 An extended period of limitation invoked by way of change of opinion is not maintainable where the statutory condition precedent for its invocation is absent; accordingly such invocation cannot sustain recovery. Where the dispute turns on interpretation of law and rival views exist and have been taken to higher fora or Larger Benches, the extended period cannot be invoked and the claim is time-barred. Applying Coordinate Bench precedent, the show cause notice issued as a change of opinion is unsustainable and the entire period is barred by limitation, producing relief for the assessee. en-us Thu, 12 Feb 2026 00:00:00 +0530 Mon, 16 Feb 2026 09:12:59 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786583 An extended period of limitation invoked by way of change of opinion is not maintainable where the statutory condition precedent for its invocation is absent; accordingly such invocation cannot sustain recovery. Where the dispute turns on interpretation of law and rival views exist and have been taken to higher fora or Larger Benches, the extended period cannot be invoked and the claim is time-barred. Applying Coordinate Bench precedent, the show cause notice issued as a change of opinion is unsustainable and the entire period is barred by limitation, producing relief for the assessee. Case-Laws Central Excise Thu, 12 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786583