No suppression of facts if assessee had a bona fide belief :
If a party bona fide believes in a legal position (e.g. that no duty is payable or no licence is required in his case) and if there is scope for such belief and doubt, penal provisions of section 11A will not apply. – Padmini Products v. CCE – 1989 (43) ELT 195 (SC) = 1989(4) SCC 275 = 1989 (25) ECR 289 (SC). = AIR 1989 SC 2278 * CCE v. Surat Textile Mills 2004 (167) ELT 379 (SC 3 member bench) * Gopal Zarda Udyog v. CCE 2005 (188) ELT 251 (SC 3 member bench) * CCE v. ITC Ltd. (2010) 257 ELT 514 (Karn HC DB).