Extended Limitation Period Unjustified Due to Unexplained Delay in CPC Case from 2013-14, Despite 2016 Memo.

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....Extended period of limitation - Clandestine Removal - excess production in respect of CPC over and above the ER 1/ER 4 return - The demand has been raised for the period 2013-14 in 2018 onwards whereas the spot memo was issued by the Department in 2016 itself. No explanation has been furthered by the Department in respect of such gross delay in proceeding with the matter. Therefore, invocation of the extended period of limitation is not justified. - AT....