In Brief
The Commissioner of Central Excise challenged a Customs, Excise and Service Tax Appellate Tribunal order that declared demand notices time-barred. The Revenue had raised substantial excise demands in the extended five-year period, despite having knowledge of the sales policy and sales agreement since 1997. The Supreme Court upheld the Tribunal's decision, holding that when materials forming the basis of a demand were known to the Revenue from the outset with no suppression or misstatement, the Revenue cannot rely on the extended limitation period. The appeals were dismissed as no substantial question of law was involved.
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