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2019 (4) TMI 484 - CESTAT NEW DELHIRectification of mistake - Held that:- The amount of entire demand, as was confirmed, stands already paid, that too without protest. This amounts to admission. Procedural law of limitation cannot supersede the substantial law of admission. Hence, irrespective there was found no wilful malafide intent on part of appellant to evade duty but fact remains is that the liability remained suppressed till it was noticed by Department. It is thereafter that the liability was discharged by the appellant. There is no error apparent on record - Application for ROM dismissed.
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