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CENVAT Credit Distribution by ISD Before April 2012 Not Liable for Repayment, No Extended Limitation Period Applicable.

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....CEVAT credit - input service distribution - distributed in proportion to the overheads of units - Rule 7 of CCR 2004 during the relevant period (prior to 01.04.12) did not prescribe any formula for distribution of cenvat credit by the ISD and therefore no liability can be fastened on them - demand not sustainable - no extended period of limitation as there is no suppression of facts....

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