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The appellant-Revenue has preferred the appeal by raising two substantial questions of law which reads as under:

1. WHETHER, under the circumstances of the case, the CESTAT is right in holding that the demand is barred by limitation on the ground that there is a bonafide belief and the clarification issued by the Bangalore Commissionerate?
2. WHETHER, the CESTAT is right in holding that the Respondent is entitled for the benefit of exemption on the basis of the Certificate said to have been issued by the CSIO Or Aeronautic Development Agency which is not a prescribed authority under the Notification No.10/97-CE dt.01/03/1997?

5. We have heard Mr.K.V.Aravind, learned Counsel appearing for the appellant and Mr.Cherian Punnoose, learned Counsel appearing for the respondent.

6. We may record that the Tribunal in the impugned order at paragraphs 9 and 10 has observed thus:

"9. As regards Notification No. 10/97-CE dated 01.03.1997 is concerned, the Revenue's objection is that the certificate produced by the assessee in terms of the said notifications are not duly signed by the proper officer. However we find that certificates handed over to the appellant duly signed by CSIO or aeronautic development agency and based on which the appellant availed the benefit of notification. Even if the fact that they were not signed by the proper officer is admitted, no suppression or misdeclaration can be attributed to the assessee so as to invoke the longer period of limitation. Apart from that we find, as is seen from the certificate, the person signing the same is holding the rank in pay scale higher than the Deputy Secretary to Government of India in which case even though the certificates were not signed by Deputy Secretary, the same should be accepted. Further the Superintendent in his letter dated 28.10.2013 has also verified the said certificates and has reported that the same appears to be adequate.