Revenue Cannot Rely On Call Book To Justify 9-Year Delay: Bombay High Court

The Bombay High Court quashed excise show cause notices issued after a delay of nine years, holding that the Revenue cannot rely on “call book” procedures to justify prolonged inaction. The Court observed that inordinate delay violates principles of fairness and legal certainty. It held that administrative inefficiencies cannot override statutory limitation periods or prejudice taxpayers. The ruling strengthens judicial scrutiny over delayed tax proceedings and reinforces the requirement for timely enforcement actions under indirect tax laws.