https://www.taxtmi.com/caselaws?id=786685 Invocation of the extended limitation under the proviso to Section 11A(1) was considered against whether the department had been unaware of material facts. The governing principle requires positive, specific findings of fraud, collusion, willful misstatement or suppression of material facts unknown to the department; generalized allegations without recorded reasons are insufficient. Applying that test, the department had prior knowledge of the arrangement through earlier circulars and decisions, and no specific findings of concealment were recorded; accordingly the extended period could not be invoked and the demand is time barred. en-us Wed, 20 Aug 2025 00:00:00 +0530 Wed, 18 Feb 2026 08:11:52 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786685 Invocation of the extended limitation under the proviso to Section 11A(1) was considered against whether the department had been unaware of material facts. The governing principle requires positive, specific findings of fraud, collusion, willful misstatement or suppression of material facts unknown to the department; generalized allegations without recorded reasons are insufficient. Applying that test, the department had prior knowledge of the arrangement through earlier circulars and decisions, and no specific findings of concealment were recorded; accordingly the extended period could not be invoked and the demand is time barred. Case-Laws Central Excise Wed, 20 Aug 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786685