https://www.taxtmi.com/caselaws?id=796049 Extended limitation cannot be invoked to recover annual differential refund amounts taken as suo motu credit where the credits were disclosed in monthly duty-payment statements and separately communicated to the Department. As the Department did not dispute entitlement to the underlying refunds and possessed all material facts concerning the credits, no suppression, fraud, or mala fide intent to evade duty was established. The notice relying on the extended period was therefore time-barred, and the resulting demand proceedings were unsustainable. en-us Mon, 27 Jul 2026 00:00:00 +0530 Fri, 31 Jul 2026 08:27:55 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796049 Extended limitation cannot be invoked to recover annual differential refund amounts taken as suo motu credit where the credits were disclosed in monthly duty-payment statements and separately communicated to the Department. As the Department did not dispute entitlement to the underlying refunds and possessed all material facts concerning the credits, no suppression, fraud, or mala fide intent to evade duty was established. The notice relying on the extended period was therefore time-barred, and the resulting demand proceedings were unsustainable. Case-Laws Central Excise Mon, 27 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796049