https://www.taxtmi.com/caselaws?id=790758 Rule 6 of the Cenvat Credit Rules did not justify a blanket percentage reversal on exempted turnover where the assessee had taken only proportionate credit for taxable output services and capital goods credit not barred by the exclusivity condition in Rule 6(4). The percentage-based demand was therefore inconsistent with the statutory scheme and failed on merits. The extended period of limitation also could not be invoked because the assessee was registered, filed ST-3 returns, and the record disclosed the credit pattern; without suppression or wilful misstatement with intent to evade tax, extended limitation was unavailable. The demand and penalty were unsustainable. en-us Thu, 26 Mar 2026 00:00:00 +0530 Thu, 30 Apr 2026 07:19:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790758 Rule 6 of the Cenvat Credit Rules did not justify a blanket percentage reversal on exempted turnover where the assessee had taken only proportionate credit for taxable output services and capital goods credit not barred by the exclusivity condition in Rule 6(4). The percentage-based demand was therefore inconsistent with the statutory scheme and failed on merits. The extended period of limitation also could not be invoked because the assessee was registered, filed ST-3 returns, and the record disclosed the credit pattern; without suppression or wilful misstatement with intent to evade tax, extended limitation was unavailable. The demand and penalty were unsustainable. Case-Laws Service Tax Thu, 26 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790758