Delayed Show Cause Notice Invalidates Extended Limitation Period Due to Unjustified Delay Beyond One-Year Audit Conclusion.

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....Extended period of limitation - In the present case, what is seen is that the audit was conducted between June 17, 2011 to June 22, 2011 and the show cause notice refers to this audit only. The notice, therefore, should have been issued within one year from the relevant date and there is no good reason as to why the Central Excise Officer should have waited till March 19, 2015 to issue the show cause notice. The extended period of limitation, for this reason alone, could not have been invoked. - AT....