Extended Limitation Cannot Be Invoked Once Facts Disclosed In Returns: CESTAT

The CESTAT held that the extended limitation period under excise law cannot be invoked if all material facts were already disclosed in the taxpayer’s returns. The bench stated that suppression or misrepresentation cannot be presumed when disclosures are transparent. The order shields taxpayers from arbitrary reopening of settled matters and underscores that revenue authorities must act within statutory timelines unless deliberate evasion is demonstrated.