TaxTMI 
TaxTMI 
2005 (10) TMI 92
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....05 (179) E.L.T. 257]. Thereafter I.A. Nos. 19 to 24 of 2005 were filed seeking a clarification that the question of limitation, even though raised, had not been dealt with by this Court in the above mentioned Judgment. On finding that the question of limitation had been argued and had not been dealt with, this Court restored these Appeals for the limited aspect of considering limitation. The Judgm....
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....] wherein it has been held that change of opinion based on a trade notice can only operate prospectively. In this Judgment it has been noticed that the concerned trade notice itself clarified that it would operate "henceforth". Therefore this Court held that classification pursuant to the trade notice can only be prospective. The Tribunal has therefore held that the demands for a period prior to t....
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....tices were dated 31st of May, 1990. They were thus prior to the circular dated 23rd October, 1990. Therefore, it is surprising that the Tribunal still concludes that the demand notices were based on that circular. Even otherwise, this circular is merely clarificatory. It does not provide that the classification as per the Circular, can only be after the date of the circular. The submissions made b....