Extended period of limitation not invocable as mandatory twin factors missing

Commissioner of Central GST and Central Excise Vs Krishi Rasayan Exports Pvt. Ltd. (Jammu & Kashmir High Court) Jammu Kashmir High Court held that the extended period of limitation as provided under provision to sub -section (1) of Section 11A was not invocable for the simple reason that the twin factors which are sine quo non for invoking the proviso were missing. Facts- The respondent is engaged in manufacturing of various products like Pesticides, Insecticides, Herbicides and Plant Growth Regulators and has established its unit at SIDCO Industries Complex, Samba. The respondent being el...