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Incorrect belief on classification/valuation doesn't invoke extended limitation period.

The CESTAT determined that the extended period of limitation under Section 11A(4) of the Central Excise Act requires a deliberate attempt to evade duty payment. An incorrect belief by the assessee regarding classification or valuation does not amount to suppression of facts. The decision referenced Supreme Court precedents in Pushpam Pharmaceuticals and Easland Combines. As there was no suppression of facts by the assessee, invoking the extended limitation period was unjustified, leading to the appeal being allowed. .....

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