Late Fee for Excise Return Filing Challenged: Department Delayed Action Since 2014, 2019 Scrutiny Insufficient for Extension.

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....Imposition of late fee for filing Central Excise return - the factum of said delay was in the notice of department since December’ 2014. Raising this issue in ACS scrutiny of the year 2019 cannot give the benefit to the department for invoking the extended period of limitation. - AT....