https://www.taxtmi.com/caselaws?id=791664 After amalgamation, clearances between units treated as the same legal entity are not transfers between distinct persons, so related-person valuation does not apply and cost-based captive consumption valuation is the correct method. Revenue neutrality, regular return filing, and departmental knowledge through audit and records mean suppression with intent to evade is not established, so the extended limitation period, interest, and penalty cannot stand. A procedural delay in availing otherwise admissible Cenvat credit does not justify denial where receipt and use of inputs are undisputed. en-us Wed, 13 May 2026 00:00:00 +0530 Fri, 15 May 2026 09:15:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=791664 After amalgamation, clearances between units treated as the same legal entity are not transfers between distinct persons, so related-person valuation does not apply and cost-based captive consumption valuation is the correct method. Revenue neutrality, regular return filing, and departmental knowledge through audit and records mean suppression with intent to evade is not established, so the extended limitation period, interest, and penalty cannot stand. A procedural delay in availing otherwise admissible Cenvat credit does not justify denial where receipt and use of inputs are undisputed. Case-Laws Central Excise Wed, 13 May 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=791664