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2018 (6) TMI 1337 - AT - Central ExciseInvocation of Extended period of Limitation - intent to evade absent - revenue neutral situation - Held that:- The transactions were duly recorded in the books of accounts ordinarily maintained by the appellant. There is no element of any suppression or contumacious conduct and/or any falsification of records on the part of the appellant - Further this situation is wholly Revenue neutral as the Cenvat Credit is stated to be disallowed to unit-I for input service was allowable to unit-2 as input service. The show cause notice is not maintainable for invoking the extended period of limitation - appeal allowed - decided in favor of appellant.
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