Intended use exemption for naphtha upheld; extended limitation rejected for lack of deliberate suppression and revenue neutrality.

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....Naphtha procured under exemption notifications for use in the manufacture of fertilizer or ammonia qualified for concessional or nil duty when the goods were intended for that use, even if a portion of the input was diverted to electricity generation that also supported the fertiliser plant. The Court held that the notifications required proof of intended use, not exclusive actual end-use in every downstream stage, so the duty demand on alleged non-eligible use failed. On limitation, extended period invocation required deliberate suppression, fraud, collusion, wilful misstatement, or contravention with intent to evade duty; those elements were absent, the matter was interpretational, and the dispute was revenue neutral. The demand and penalty were therefore time-barred.....