Appellants' SSI exemption claim dismissed due to suppressed facts; extended assessment period justified. No bona fide belief in NIL duty.

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....SSI Exemption - use of brand name of others - There is no ambiguity in the wordings of the Notification. Therefore, there are no reason for the appellants to entertain any doubts regarding the notification. The appellant’s submission that they had a bona fide belief that goods attracted NIL rate of duty was same as non-excisable goods. There is no merit in the argument. - it can only be concluded that the appellants have suppressed material facts from the Department. In such circumstances, the extended period is rightly invokable. - AT....