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2012 (12) TMI 470 - CESTAT, CHENNAIExtended period of limitation – Held that:- There is no challenge by the department to the finding of the lower appellate authority on the question of limitation. As such, the Tribunal cannot go into the question that has not been raised by the department. Besides, when the relief has been given on two grounds i.e., both on merits and on limitation, and the department has chosen not to challenge the same on the count of limitation, it would be an infructuous exercise to go into the appeal on the ground of merit because the respondents would get the benefit in any case on the ground of limitation since the entire demand is for the extended period.
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