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    <title>2026 (3) TMI 504 - CESTAT CHANDIGARH</title>
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    <description>Modvat credit on GP sheets could not be denied on a mere allegation of clandestine diversion where the Revenue relied only on the fact of purchase and the general industry practice of using HR/CR sheets for OE parts, without concrete evidence of diversion, identified buyers, or proof of alternative procurement. The denial of credit therefore failed. The extended period of limitation was also unavailable because the credit was recorded in statutory records, invoices were filed with the department, and returns were regularly submitted and assessed, showing departmental knowledge of the material facts. The demand was accordingly held barred by limitation, and consequential relief followed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=787749</link>
      <description>Modvat credit on GP sheets could not be denied on a mere allegation of clandestine diversion where the Revenue relied only on the fact of purchase and the general industry practice of using HR/CR sheets for OE parts, without concrete evidence of diversion, identified buyers, or proof of alternative procurement. The denial of credit therefore failed. The extended period of limitation was also unavailable because the credit was recorded in statutory records, invoices were filed with the department, and returns were regularly submitted and assessed, showing departmental knowledge of the material facts. The demand was accordingly held barred by limitation, and consequential relief followed.</description>
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