Commissioner Of Central Excise, Bombay vs M/S. Reliance Industries Ltd

The Supreme Court upheld the decision of the Customs Excise and Gold (Control) Appellate Tribunal (CEGAT) which quashed the order of the Collector of Central Excise, confirming a demand of duty and imposing penalties under Rule 173Q of the Central Excise Rules, 1944. The Court found that the extended period of limitation under Section 11A of the Central Excise Act, 1944 was not applicable as there was no specific allegation of suppression or fraud. The Court emphasized the necessity of clear evidence for invoking the extended limitation period, thereby reinforcing the principle of fair notice in tax assessments.