be a case for invoking the extended period of limitation. In such cases, only the normal period of limitation will apply.
Saloni Roy, senior director, Deloitte India, said an assessee (who may belong to any industry), who sells goods for an extended period to increase his market penetration at a value lower than his cost and declares his transaction value at such lower value, faces the risk of litigation.
The interpretation by the SC as well as the circular are not entirely in tandem with the understanding of the excise provisions by the trade and industry. “It would, therefore, be preferable that amendments are made in the legal provisions, in case the Fiat judgment is to be implemented so that ambiguities are removed,” said Roy.