2010 (7) TMI 381

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..... not disputed that they were not entitled to credit but only argued that the demand is barred by limitation as there was no suppression on their part and therefore, notice should have been issued within the normal period of limitation - They submit that at the time of taking the credit of tax paid by mistake, they were under the bona fide belief that they were eligible to credit - extended period .....

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..... the time of taking the credit of tax paid by mistake, they were under the bona fide belief that they were eligible to credit. I find that there is no basis for the bona fide belief that they were entitled to credit. The fact of taking credit was not disclosed to the authorities and therefore, extended period of limitation has rightly been invoked against the assessees. In view of the matter, I ho .....

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