https://www.taxtmi.com/caselaws?id=52835 The extended period of limitation could not be invoked for duty demand on undervaluation of intermediate goods cleared to sister units because the assessee had followed the valuation method then prevailing and filed cost certificates based on the instructions available at the time. The disputed period also preceded the Board circular relied on by the department. As the goods moved within the same assessee's manufacturing chain, any duty paid at the source unit would have been available as credit in the receiving unit, creating revenue neutrality. In the absence of evidence of wilful suppression or intent to evade duty, the ingredients for extended limitation and penal consequences were not established, and the demand failed. en-us Thu, 08 Apr 2004 00:00:00 +0530 Mon, 15 Jul 2024 12:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=52835 The extended period of limitation could not be invoked for duty demand on undervaluation of intermediate goods cleared to sister units because the assessee had followed the valuation method then prevailing and filed cost certificates based on the instructions available at the time. The disputed period also preceded the Board circular relied on by the department. As the goods moved within the same assessee's manufacturing chain, any duty paid at the source unit would have been available as credit in the receiving unit, creating revenue neutrality. In the absence of evidence of wilful suppression or intent to evade duty, the ingredients for extended limitation and penal consequences were not established, and the demand failed. Case-Laws Central Excise Thu, 08 Apr 2004 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=52835