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2018 (6) TMI 373 - AT - Central ExciseExtended period of limitation - intent to evade - CENVAT credit - appellants had paid Engineering fees / Royalty / Technical Consultancy fees - reverse charge - the appellant had received the services only prior to 10.9.2004 - Held that:- The period involved in the notice is March 2005 & March 2006. However, the SCN has been issued only on 5.3.2008 - there are no ingredients which can justify the invocation of extended period of limitation - the proceedings are ab initio hit by limitation - appeal allowed on limitation.
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