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    <title>2025 (8) TMI 1826 - CESTAT BANGALORE</title>
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    <description>Failure to file the Rule 6(3A) option letter did not extinguish the substantive right to reverse CENVAT credit proportionately for input services used in both taxable and exempted trading activity; the attributable credit could still be worked out and reversed on a proportionate basis. The extended period of limitation could not be invoked where the transactions were reflected in books and returns and there was no wilful suppression with intent to evade, so the related penalty also could not survive. The matter was remanded for fresh determination of any normal-period liability after examining whether the reversal already made was in accordance with law.</description>
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    <pubDate>Fri, 29 Aug 2025 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=469196</link>
      <description>Failure to file the Rule 6(3A) option letter did not extinguish the substantive right to reverse CENVAT credit proportionately for input services used in both taxable and exempted trading activity; the attributable credit could still be worked out and reversed on a proportionate basis. The extended period of limitation could not be invoked where the transactions were reflected in books and returns and there was no wilful suppression with intent to evade, so the related penalty also could not survive. The matter was remanded for fresh determination of any normal-period liability after examining whether the reversal already made was in accordance with law.</description>
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