Passing remarks by Tribunal while deleting penalty won’t negate invocation of extended limitation pe

Excise & Customs : Where Tribunal found that assessee, a manufacturer of dutiable and exempted goods, did not comply with Cenvat rule 6 with an intent to evade duty and confirmed demand invoking extended period, such demand does not become invalid even if Tribunal has deleted penalty observing 'there was no intent to evade'