Department's Attempt to Invoke Extended Limitation Period Deemed Improper Due to Lack of Evidence Suppression by Appellants.

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....Invocation of Extended Period of Limitation - though the department was informed as early as February 2001 took note of the ineligibility of the Notification in June 2003 by which the time limit prescribed for issuance of show cause notice for duty not paid not levied as already expired. - The department to cover up their inaction immediately after the submission of the said letter by the Appellants have taken recourse to invocation of extended period. We find that this is not legal and proper. No material evidence has been suppressed by the Appellants with intent to evade payment of applicable duty. - AT....