ORDER : 1. Heard the learned counsel for the parties in these appeals. 2. Our attention is drawn to the impugned judgment and order passed by CEGAT, West Regional Bench at Mumbai on 29-9-2000. By the said judgment, the two-Judge Bench of the Tribunal, after referring to the larger Bench decision in Jay Yuhshin Ltd. v. CCE, (2000) 119 ELT 718 (Tri) held that the finding of the Commissioner that revenue neutrality is not established by the appellants is factually incorrect and, therefore, the order of the Commissioner is required to be set aside. By the said order, the Tribunal held that since it is a case resulting in revenue neutral situation, therefore, the extended period of limitation is not applicable and the entire demand is barred by limitation. 3. Our attention is also drawn to the decision of the larger Bench, a copy of which is annexed to the paper book. In the operative portion of the judgment, the larger Bench of the Tribunal has answered the reference in the following manner: (ELT p. 725, para 13) "(a) revenue neutrality being a question of fact, the same is to be established in the facts of each case and not merely by showing the availability of an alternate scheme; (b) where the scheme opted for by the assesses is found to have been misused (in contradistinction to mere deviation or failure to observe all the conditions) the existence of an alternate scheme would not be an acceptable defence; (c) with particular reference to MODVAT Scheme (which has occasioned this reference) it has to be shown that the revenue neutral situation comes about in relation to the credit available to the assesses himself and not by way of availability of credit to the buyer of the assessess manufactured goods; (d) we express our opinion in favour of the view taken in International Auto Ltd. v. CCE, (2005) 12 SCC 129 : (2005) 183 ELT 239 and endorse the proposition that once an assesses has chosen to pay duty, he has to take all the consequences of payment of duty." 4. There are four areas laid down therein and it appears to us that the decision was rendered by the Tribunal only by reference to clause (c) thereof, whereas clauses (a), (b) and (d) do not appear to have been taken notice of or considered by the Division Bench of the Tribunal in the impugned judgment and order. A bare reading of the order of the Tribunal makes the position crystal clear that there is no proper discussion of all the factual issues arising for consideration. 5. The learned counsel appearing for the respondents has drawn our attention to the judgment of this Court in International Auto Ltd. v. CCE, (2005) 12 SCC 129 : (2005) 183 ELT 239 whereby this Court has set aside the judgment delivered by the Tribunal in CAs Nos. 4086-87 of 2001. The learned counsel appearing for the appellant has also drawn our attention to the decisions of this Court in Amco Batteries Ltd. v. CCE (2003) 4 SCC 41 , CCE v. Mahindra & Mahindra Ltd., (2005) 10 SCC 253 Dharampal Satyapal v. CCE (2005) 4 SCC 337 : (2005) 183 ELT 241 ; I.F.B. Industries Ltd. v. CCE, (2005) 179 ELT 487 (Tri) and Kubo Combustion Efficiency Chemical (P) Ltd. v. CCE, (2008) 225 ELT 391 (Tri). There is yet another decision of this Court in Union of India v. Rajasthan Spg. & Wvg. Mills, (2009) 13 SCC 448 wherein also principles and circumstances in which extended period of limitation would be applicable have been discussed. 6. The learned counsel for the respondents, during the course of his argument, has also relied on the decision in Commr. v. Essel Propack Ltd., Civil Appeals Nos. 2804-806 of 2004, decided on 11-10-2006 (SC) apart from the decision in International Auto Ltd. v. CCE, (2005) 12 SCC 129 : (2005) 183 ELT 239 . 7. These decisions which deal with the issues as to when and how the extended period of limitation could be said to be applicable are directly on the issue raised. 2804-806 of 2004, decided on 11-10-2006 (SC) apart from the decision in International Auto Ltd. v. CCE, (2005) 12 SCC 129 : (2005) 183 ELT 239 . 7. These decisions which deal with the issues as to when and how the extended period of limitation could be said to be applicable are directly on the issue raised. There is no proper discussion and finding with regard to the factual position by the Tribunal in the present case and, therefore, we set aside the impugned judgment and order and remit back the matter to the Tribunal for de novo and fresh consideration of the issues which arise for consideration both in respect of the factual position as also the legal position in the light of the aforesaid decisions of this Court and also of the Tribunal. We request the Tribunal to consider and dispose of the matter as expeditiously as possible. 8. With the above observations, the appeals stand disposed of leaving the parties to bear their own costs. We also make it clear that we have not expressed any views or opinion on the merits of the claims and disputes between the parties.