2026 (9) TMI 343

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..... JUSTICE ROHIT KAPOOR Present:   For the Appellant: Mr. Ajay Kalra, Senior Standing Counsel and Ms. Isha Janjua, Advocate. For the Respondent: Mr. B. L. Narasimhan, Advocate (through video conferencing) and Ms. Krati Singh, Advocate and Ms. Khushi Satviki, Advocate. ASHWANI KUMAR MISHRA, A.C.J. (ORAL) 1. This appeal is by the revenue assailing the judgment and order dated 11.0....

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....none of the circumstances existed which justified the invocation of jurisdiction by extending the period of limitation. 3. The only ground on which the revenue has challenged the judgment of the Tribunal is that two letters dated 17.02.2011 and 08.03.2011 contained a wrong intimation to the Department by the respondent that it had not availed any credit till that date on inputs/input services u....

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....ed question of law and fact. 6. The findings returned by the Tribunal on this aspect are based upon an appreciation of the evidence placed on record. The Tribunal has also noticed that the two letters relied upon by the Department were not placed on record before the Tribunal. 7. In such view of the matter, the appreciation of facts by the Tribunal on the relevant aspects does not call for a....