https://www.taxtmi.com/caselaws?id=797121 Clandestine manufacture, removal and undervaluation cannot be established solely from mismatches in ER-1, ER-4 and ER-6 returns, trial balance figures, or estimated input-output ratios. Cogent corroboration, such as evidence of excess raw-material procurement or consumption, electricity use, labour, transport, buyers, sale proceeds, or unaccounted transactions, is required; reconciliations and a Chartered Accountant's certificate may explain discrepancies. Auto-generated ER-4 inventory and production values do not by themselves prove actual sale value or differential consideration. Extended limitation cannot rest on suppression where the relevant returns and accounts were disclosed and the same facts were already known through earlier proceedings. Duty demands on these grounds are unsustainable. en-us Tue, 21 Jul 2026 00:00:00 +0530 Tue, 18 Aug 2026 08:35:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=797121 Clandestine manufacture, removal and undervaluation cannot be established solely from mismatches in ER-1, ER-4 and ER-6 returns, trial balance figures, or estimated input-output ratios. Cogent corroboration, such as evidence of excess raw-material procurement or consumption, electricity use, labour, transport, buyers, sale proceeds, or unaccounted transactions, is required; reconciliations and a Chartered Accountant's certificate may explain discrepancies. Auto-generated ER-4 inventory and production values do not by themselves prove actual sale value or differential consideration. Extended limitation cannot rest on suppression where the relevant returns and accounts were disclosed and the same facts were already known through earlier proceedings. Duty demands on these grounds are unsustainable. Case-Laws Central Excise Tue, 21 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=797121