Extended Limitation for Duty Requires Deliberate Act, Not Just Inaction, Says Supreme Court.

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....Extended period of limitation - demand of duty - it is settled legal principle as laid down by the Hon’ble Supreme Court in catena of decisions that something positive other than mere inaction or failure on the part of the manufacturer or producer or conscious or deliberate withholding of information when the manufacturer knew otherwise, is required before the assessee is saddled with any duty liability. Therefore, mere short payment of duty by the appellant is not sufficient in order to invoke the extended period. - AT....