VidhiSangh

Supreme Court of India · 04/07/2023

COMMISSIONER, CENTRAL EXCISE AND CUSTOMS AND ANOTHER versus M/S RELIANCE INDUSTRIES LTD.

[2023] 9 S.C.R. 1286 · 2023 INSC 591

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Summary

The Court dismissed the Revenue’s appeals because the differential excise-duty demands were time-barred. The assessee’s valuation followed a then-prevailing Tribunal decision, supporting a bona fide belief, and no required disclosure had been withheld. The later reversal of that decision did not establish deliberate suppression. Valuation merits and revenue neutrality were expressly left undecided.

Issues

  1. Whether reliance on a prevailing Tribunal interpretation and the disclosures made permitted invocation of the extended limitation period for alleged suppression.
  2. Whether the Revenue could support extended limitation through new oral grounds not raised in its appeal.

Provisions considered

Held

Result

Revenue’s appeals dismissed because the demands were time-barred. Merits of valuation and revenue neutrality expressly left open.

Judgment PDF: Supreme Court of India, [2023] 9 S.C.R. 1286.