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2019 (7) TMI 1012 - AT - Central ExciseCENVAT Credit - input services through ISD invoices passed on by their head office - construction service - period May 2012 to January 2014 - Suppression of facts or not - invocation of Extended period of Limitation - HELD THAT:- In the present case, the period involved is May 2012 to January 2014 and the SCN is dated 17.11.2016. From the documents placed on record there have been queries and replies by the assessee and one of the earliest queries by the Revenue is dated 20.09.2013. There were also replies filed on various dates and one of such replies is dated 10.06.2014 wherein, the details have been explained very clearly covering all the points in dispute. These points clearly show that the Revenue was in fact aware of the activities of the appellants. The stand of the Revenue as to suppression is, therefore, only on imaginations, which is not supported by any documentary evidence, which cannot sustain. Revenue has miserably failed to justify invoking larger period of limitation and therefore, the impugned order cannot sustain. Hence the same is set aside. Appeal allowed on limitation.
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