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1. By the impugned order No. 9/99 dated 30.7.1999, the Commissioner has taken a view that the assessee being manufactures of Linear Benzene Sulphuric Acid (LABSA in short), which is commonly called Acid slurry, has undervalued the goods while selling the same to various customers viz. M/s. Hindustan Lever Limited, M/s. Naga Detergents (P) Ltd., M/s. Super Chem Industries, M/s. Alpha Detergents (P) Ltd., M/s. Kelkar Industries, M/s. Vivid Detergents Limited etc. He has held that the clearances made on the job 'work basis were on higher value. It has been alleged that the Commissioner has held that the appellants had deliberately created the gradation only to avoid the adoption of independent selling prices available for comparable goods for the purpose of assessment of the consignments; that they had wilfully mis-led the department by artificially creating two different grades of LABSA only to evade Central Excise Duty by under valuing LABSA manufactured/cleared by them on job work basis. Initially a Show Cause Notice had been issued by the Superintendent on 30.1.1997 on the same ground. The officers had already visited factory in 1996 and had taken all the details and, therefore, the Show Cause Notice subsequently issued on 18.9.1998 on the same ground alleging suppression is barred by time. They had submitted that without prejudice, they had, on being persuaded and coerced had paid duty by TR 6 Challans, to an extent of Rs. 21,37,551/-for clearance made during the period November 1995 up to February 1997, arising from Show Cause Notice dated 30.1.1997. Therefore, they submit that subsequent Show Cause Notice dated 18.9.1998 covering period January 1996 to September 1996 is not sustainable. In this regard, they rely on judgments rendered in the case of Neyveli Lignite Corporation v. CCE wherein it has been held that extended period of limitation is not applicable when a demand for a subsequent period been raised under normal limitation and demand for earlier period raised subsequently. They rely on the following judgments on the issue of time bar.