Case Law Analysis
|Custom, Excise & Service Tax Tribunal
Extended Limitation Period Not Invocable Without Suppression: CERA Audit Dispute Does Not Constitute Fraudulent Omission | CESTAT Chennai
CESTAT Chennai rules that when the tax department itself disputes a CERA audit objection, no suppression of facts exists-even if tax is later demanded-making the extended limitation period inapplicable. This protects taxpayers from retrospective demands based on internal audit disagreements, reinforcing that mere procedural objections don't equate to concealment under Section 73 of the Finance Act, 1994.