Extended period of limitation cannot be invoked for recovery of excise duty

Commissioner of CGST & Central Excise Vs Hindustan Petroleum Corporation Ltd. (Bombay High Court) In our view, any decision on the issue whether the revenue could have invoked the extended period of limitation for recovery of the excise duty, or would not have any bearing or impact on the rate of duty of excise or to the value of goods for the purposes of assessment. Such determination on the issue of limitation would also have no bearing on the issue of determination of taxability or excisability of goods for the purposes of assessment. In our view, the issue of limitation in this case be...