In absence of specific allegation & proof extended limitation period cannot be invoked

Hyundai Motors India Ltd. Vs Commissioner of GST & Central Excise (CESTAT Chennai)

It has merely stated that the fact of non-payment would not come to notice but for the verification of the audit department. In the absence of any specific allegation and proof that the appellant has suppressed facts, the extended period cannot be invoked.

In the Show Cause Notice, there is no specific allegation that the appellant has willfully suppressed or mis-represented the facts with intention to evade payment

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