Extended period of limitation cannot be invoked when all the facts were in knowledge of revenue

Raychem RPG Ltd. Vs Commissioner of Central Excise (CESTAT Mumbai)

We are not in agreement with the findings recorded by the Commissioner on the issue of limitation. Undisputedly all the facts were in the knowledge of the revenue and in fact have been corresponded between the revenue and appellant since 1993. For the clearance of the said goods either by adopting the value determined on the basis of cost construction method prior to 1994, appellants would have filed Price List as per Rule 173 C of the erstwhile Central excis

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