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    <title>2026 (4) TMI 999 - CESTAT CHANDIGARH</title>
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    <description>MODVAT/CENVAT credit denial cannot rest solely on discrepancies between balance-sheet figures, RG-23A records and later stock verification unless the Revenue produces cogent evidence of non-receipt, non-consumption or clandestine removal of inputs; on that basis, the credit demand was found unsustainable. Extended limitation is unavailable where records were maintained, returns were filed regularly, and there was no factual foundation for suppression or intent to evade duty; accordingly, the longer period could not be invoked. Proceedings and penalty must also be founded on the law in force during the relevant period, so notice and penalty under inapplicable later CENVAT Credit Rules were held legally unsustainable.</description>
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