TMI Blog2009 (5) TMI 219X X X X Extracts X X X X X X X X Extracts X X X X ..... d was barred by limitation as the assessees were under a bona fide belief that the goods were not assessable to duty. - the findings of the Commissioner (Appeals) that the assessees were under bona fide belief and therefore the demand is time-barred, has not been successfully challenged by the revenue. We therefore, uphold the impugned order and reject the appeal. - The cross objection filed by th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oor frames, seat frames supplied to Indian Railways and the Integral Coach Factory by the assessees were not semi-finished goods but fully excisable goods, held that the demand was barred by limitation as the assessees were under a bona fide belief that the goods were not assessable to duty. The contention of the assessees that they had formed the belief that goods cleared by them were not excisab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... bona fide belief and therefore the demand is time-barred, has not been successfully challenged by the revenue. We therefore, uphold the impugned order and reject the appeal. 2. The cross objection filed by the assessees wherein they have challenged the findings of the Commissioner (Appeals) that the goods sold to Indian Railways were saleable/marketable goods and were not semi-finished goods is ..... X X X X Extracts X X X X X X X X Extracts X X X X
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