Extended Limitation Not Applicable To Audit-Based Demand: CESTAT

The Customs, Excise and Service Tax Appellate Tribunal ruled that extended limitation cannot be invoked for demands arising solely from audit objections. Quashing the excise duty demand against Delphi Automotive, the Tribunal held that when facts are already available on record, allegations of suppression or wilful misstatement cannot be sustained. The decision reiterates that extended limitation is an exception and must be strictly construed, providing relief to assessees facing prolonged tax exposure based on routine audits.