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2025 (7) TMI 559

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....D. Sue, Authorized Representative for the Respondent ORDER Per Ashok Jindal : The appellant is in appeal against the impugned order. 2. The facts of the case are that the appellant is a Public Sector Undertaking and engaged in providing telecommunication services. The appellant was availing cenvat credit during the period 2005-06 to 2008-09 on the basis of "Advice of Transfer Debit Bills" issu....

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....dertaking, the extended period of limitation is not invokable. He also submits that the appellant has availed cenvat credit on the basis of "Advice of Transfer Debit Bills", which is like of credit notes and the same has been held by the Tribunal that the cenvat credit taken on the basis of credit note is admissible as the same is having all the documents as per Rule 9 (2) of the Cenvat Credit Rul....

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.... on "Advice of Transfer Debit Bills" issued by the Head Quarters. In view of this, we do not find any merit in the impugned order and the said is set aside. 7. Further, we take note of the fact that the whole of the demand has been raised against the appellant by invoking extended period of limitation. As the appellant is a Public Sector Undertaking, in that circumstances, there can be no malafid....