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    <title>2026 (5) TMI 4 - CESTAT NEW DELHI</title>
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    <description>Extended limitation could not be invoked where the taxpayer had commenced taxable activity, availed and used input service credit, and sought GST migration, because the record showed bona fide conduct rather than suppression; the show cause notice was therefore time-barred and the demand could not survive. CENVAT credit also could not be denied on the ground of delayed availment, because the Tribunal found that the credit had been taken and used within the relevant period and the objection was factually unsupported on the record. The impugned order was set aside with consequential relief.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790802</link>
      <description>Extended limitation could not be invoked where the taxpayer had commenced taxable activity, availed and used input service credit, and sought GST migration, because the record showed bona fide conduct rather than suppression; the show cause notice was therefore time-barred and the demand could not survive. CENVAT credit also could not be denied on the ground of delayed availment, because the Tribunal found that the credit had been taken and used within the relevant period and the objection was factually unsupported on the record. The impugned order was set aside with consequential relief.</description>
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