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2008 (7) TMI 367 - GUJARAT HIGH COURTDemand and Recovery – Extended period of limitation – Suppression of facts – first appellate authority perused the copies of RT-12 returns and the declaration filed under Rule 173B by the respondent assessee and recorded that in the circumstances, no suppression of facts was proved. - the entire facts were within the knowledge of the revenue when the earlier show cause notice was issued to the respondent assessee on the same ground.- there was no justification for invoking larger period of limitation in absence of any suppression of facts or misstatement with intention to evade payment of duty - it is not possible to state that any error in law has been committed by the Tribunal so as to give rise to a substantial question of law.
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