ORDER : Tarun Agarwala, J. We have heard Dr. A. Saraf, the Learned Senior Counsel appearing for the appellant and Shir N. Mozika, the Learned Counsel appearing for the Central Excise and Service Tax department. 2. The appellant was issued a show cause notice to show cause as to why the Central Excise Duty should not be demanded and recovered under Section 11A(4) of the Central Excise Act, 1944 ["hereinafter referred to as the Act"] along with interest in terms of Section 11AA and also show cause as to why penalty should not be imposed under Section 11AC(1) of the Act. The appellant objected to the show cause notice contending that the amount cannot be recovered as it was barred by limitation and the extended period of limitation as contained in the proviso to Section 11A(4) of the Act. The objection of the appellant was rejected by the Adjudicating Authority as well as by the First Appellate Authority. The matter travelled up to the Tribunal whereby, the Tribunal by the impugned order rejected the contention of the appellant with regard to the demand being barred by limitation but accepted the contention of the appellant and remitted the matter to the Adjudicating Authority to decide the issues involved afresh after taking fresh evidence if necessary. 3. The appellant being aggrieved by that part of the order of the Tribunal rejecting the contention that the demand was barred by limitation has filed the present appeal under Section 35G of the Act. 4. The Tribunal while considering the period of limitation held as follows :- "7. In some cases, it is claimed that the matter is time barred and they took the plea that the extended period is wrongly extended. After hearing the rival submissions, we re-concur with the finding of the Commissioner regarding the extended period and uphold the findings of the Commissioner. Hence, the plea of extended period is rejected." 5. We find that the Tribunal had decided 79 appeals by a common order. In our opinion, when the matter was allowed and all the issues were directed to be decided by the Adjudicating Authority de novo, it would have been appropriate for the Tribunal to also remit the matter to the Adjudicating Authority to decide the question of limitation and the extended period of limitation under Section 11A(1) read with Section 11A(4) of the Act. The authority is required to consider whether any fraud or collusion or wilful misstatement or suppression or contravention of any provision of the Act was made by the appellant in a particular case while considering the extended period of limitation. According to the appellant, the goods were declared on the basis of their belief of the interpretation of law that the exempted goods were not required to be included and that it did not include the value of remission at the relevant time. In the light of the stand of the appellant, we are of the opinion that the question of limitation and extended period of limitation is required to be considered in this light. We find that the Tribunal was therefore required to consider the period of limitation in each and every case and could not have rejected the contention of the appellant by a sweeping statement, namely, "we re-concur with the finding of the Commissioner." We are further of the opinion that the Tribunal, being the last fact finding authority was required to give its own reasons which it has failed miserably. 6. Accordingly, we are of the opinion that since the Tribunal has remitted the matter to the Adjudicating Authority for re-consideration on all the issues de novo with further directions that additional evidence can also be adduced by the parties, we are accordingly of the opinion that the question as to whether the show cause notice was issued within the period of limitation or otherwise needs to be considered and adjudicated afresh by the Adjudicating Authority. 7. We accordingly allow the appeal at the admission stage without calling for a counter affidavit. Since the matter is already remitted to the Adjudicating Authority, we modify the order of the Tribunal to the extent that the Adjudicating Authority, while deciding all the issues, will also decide the issue with regard to the applicability of the period of limitation and the extended period of limitation in issuance of demand notice by the respondents.