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2020 (4) TMI 470 - AT - Central ExciseExtended period of limitation - CENVAT credit - inputs issued by the units, who are availing exemption under Notification No. 01/10-CE dt. 06.02.2010 - area based exemption - credit denied on the premise as per Notification No. 02/14-CE (N.T.) dt. 20.01.2014, the appellant was not entitled to credit prior to the Notification No. 01/10-CE dt. 06.02.2010 - period involved in this case is 01.06.2012 to 19.01.2014 but SCN issued by invoking extended period on 21.06.2017. HELD THAT:- In their own case M/S. B.R. AGROTECH LTD. VERSUS CCE & ST, JAMMU [2018 (10) TMI 1828 - CESTAT CHANDIGARH] for the same period, this Tribunal has already held that extended period of limitation is not invokable holding that when the Revenue is having divergent views on the issue, the extended period of limitation is not applicable. The extended period of limitation is not invokable - appeal allowed - decided in favor of appellant.
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