Belated return filing fixes the relevant date for limitation, sustaining royalty duty only within the normal period.

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....Where a return is filed belatedly, the actual date of filing is the relevant date for limitation, and the due date applies only when no return is filed. On that basis, the Tribunal held the show cause notice to be within the normal period and sustained the royalty-related excise duty only for the period within time. The entire demand on stowing excise duty was set aside as unsustainable, and the interest demand on the royalty component was also waived and set aside.....