AUDI AUTOMOBILES Vs. COMMISSIONER OF CENTRAL EXCISE

JUDGEMENT

(1.) The issue raised in the above cases is in a narrow compass as to whether the extended period of limitation under the proviso to Sec. 11A is available to the Central Excise and Service Tax Department (for short, 'the Department ').

(2.) We heard Ms. Charanya Lakshmikumaran, learned AoR appearing for the appellants and Ms. Nisha Bagchi, learned Senior Counsel appearing for the respondent-Department.

(3.) A preliminary objection was raised by Ms. Bagchi that the appeal would not come within the contours of Sec. 35L of the Central Excise Act, 1944, the issue agitated having no relation to any question involving the rate of duty of excise or to the valuation of goods for purposes of assessment. The learned Senior Counsel relied on SAIL v. Directorate General of Anti- Dumping & Allied Duties; (2017) 13 SCC 1 and Commissioner of Customs v. Motorola (India) Ltd.; (2019) 9 SCC 563.