https://www.taxtmi.com/caselaws?id=798317 Extended limitation for recovery proceedings was unavailable because the assessee had already disclosed material facts on common inputs and input services and Cenvat credit availment. Departmental letters did not provide fresh information capable of supporting invocation of the extended period, and they were not part of the Tribunal's record. As limitation involved mixed questions of law and fact, the Tribunal's factual appreciation did not warrant interference within limited appellate jurisdiction. The limitation issue was resolved in favour of the assessee. en-us Wed, 26 Aug 2026 00:00:00 +0530 Sat, 05 Sep 2026 08:44:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798317 Extended limitation for recovery proceedings was unavailable because the assessee had already disclosed material facts on common inputs and input services and Cenvat credit availment. Departmental letters did not provide fresh information capable of supporting invocation of the extended period, and they were not part of the Tribunal's record. As limitation involved mixed questions of law and fact, the Tribunal's factual appreciation did not warrant interference within limited appellate jurisdiction. The limitation issue was resolved in favour of the assessee. Case-Laws Central Excise Wed, 26 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798317