Limitation period cannot be invoked on the issue of interpretation

Arihant Tradelinks India Private Limited Vs C.C.E., Kutch (Gandhidham) (CESTAT Ahmedabad) Conclusion: In present facts of the case, the Hon’ble Tribunal held that limitation period could not be invoked as the issue involved is purely of interpretation of Cenvat Credit Rules, levy of CVD in terms of Customs Tariff Act, therefore malafide intention cannot be attributed to the appellant. Facts: The brief facts of the case are that the appellants have availed Cenvat credit of CVD paid on input namely, coal of various types either directly imported by the appellant or purchased from other importe...