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2020 (2) TMI 387

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..... findings have not been placed on record on the same - Perusal of show cause notice would reveal that for contravention of provision of Rule 2 3 of Cenvat credit rule and Rule 4, 6, 8 11 of Central Excise Rules 2002, the demand was raised and it was confirmed in the OIO and OIA on the ground that appellant had suppressed the fact that they were availing Cenvat Credit of service tax on such ser .....

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..... U KUMAR PATI: Application for rectification of mistake in the order No. A/85354/18 passed on 22-02-2018 under Section 35C (2) of the Central Excise Act 1944, which was heard on 05-07-2019, taken up for orders today. 2. Learned Counsel for the appellant Mr. J.C. Patel submitted that plea of limitation, which was taken as primary ground of appeal in para VI and VII of the appeal memo and pla .....

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..... ch submissions, argued that clear finding was given in para 4 of the order of the Tribunal that submission made by both the sides were carefully considered and all judgements relied upon by the appellant would not be of any help to the appellant. Therefore, the ground raised in the rectification application that without any finding was given on invocation of extended period the order was passed wa .....

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..... cation is sought by the appellant. There is no denial of the fact that the points raised concerning non-application of extended period of limitation has not been specifically dealt with and findings have not been placed on record on the same. Perusal of show cause notice would reveal that for contravention of provision of Rule 2 3 of Cenvat credit rule and Rule 4, 6, 8 11 of Central Excise Rul .....

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