Extended period of limitation not invocable on account of revenue-neutrality

Indo Shell Cast Pvt. Ltd Vs commissioner of GST & Central Excise (CESTAT Chennai) CESTAT Chennai held that demand invoking extended period cannot be sustained on account of revenue-neutrality as duty charged by Unit-I would be taken as cenvat credit by Unit-II. Facts- The appellant is Unit-II and is engaged in the manufacture of rough castings. These rough castings are supplied to Unit I for further processing into machined castings. On verification of records, it was found that appellant (Unit II) transferred their products to Unit I on stock transfer basis by paying duty adopting the val...