Extended Limitation Period Invalid Without Allegation of Intent to Evade Duty u/s 11A(4) in Show Cause Notice.

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....Invocation of extended period of limitation - In the absence of any allegation made in the show cause notice that the appellant had suppressed facts with intent to evade payment of duty, the Department could not have invoked the extended period of limitation under section 11A(4) of the Act. This issue was raised by the appellant before the Commissioner (Appeals), but no finding has been recorded. - The extended period of limitation could not have been invoked. - AT....