JUDGMENT 1. The Revenue is in appeal against the order of the tribunal dated 18th March, 2015. The tribunal had before it the Revenue''s appeal challenging the order of the Commissioner of Central Excise (Appeals) dated 18th March, 2015. The Commissioner (Appeals) had set aside the order-in-original only on the point of limitation. The argument before the Commissioner (Appeals) was that the assessee was engaged in the manufacture of electric wires and cables for industrial purpose classifiable under Chapter 85.44 of the First Schedule to the Central Excise Tariff Act, 1985. A show cause notice dated 1st December, 2005 was issued, proposing demand of duty for the period from December, 2000 to March, 2003 along with interest and to impose penalty on the ground that the assessee wrongly availed of the benefit of exemption notification on electric wires classifiable under subheading no. 5402.49 manufactured and cleared by the assessee as parts of non-conventional energy device/system other than wind operated. The adjudicating authority confirmed the demand of duty along with interest and also imposed penalty. 2. The Commissioner (Appeals) set aside that order by holding that the demand is barred by limitation and without going into the merits of the case. 3. Ms. Cardozo appearing for the revenue would argue, as before the tribunal, that the appeal raises substantial questions of law. She would submit that if the finding on limitation is perverse, in the sense no reasonable person placed in the position of an adjudicator, impartial and independent, would arrive at the conclusion, which is arrived at in the present case, then, we should entertain this appeal. She would submit that the tribunal has failed in its duty as a last fact finding authority, as it did not apply its independent mind, but merely endorsed the finding of the Commissioner (Appeals). Hence, this appeal, which proposes the substantial questions of law, should be admitted and consequently allowed. 4. Upon perusal of the appeal paper book and particularly the order under appeal, we are unable to agree. The tribunal must perform its duty as a last fact finding authority is indeed an unassailable legal proposition. However, it has performed it or otherwise would depend on the facts and circumstances of each case and we must find out whether in this case the tribunal has failed in its duty expected from it to be performed in law. The tribunal must perform its duty as a last fact finding authority is indeed an unassailable legal proposition. However, it has performed it or otherwise would depend on the facts and circumstances of each case and we must find out whether in this case the tribunal has failed in its duty expected from it to be performed in law. It is not fair to read only one paragraph of the order under appeal or by picking out some sentences therefrom. To read the order in appeal in such a manner and consider the finding in isolation would be unjust and unfair. The Commissioner (Appeals) in this case held that the assessee was expected to perform certain duty and that is of full disclosure of facts. In the present case, the assessee was visited with a show cause notice of 9th December, 2005. That followed a show cause notice of 9th September, 2003, which was issued in the normal period of one year and duly adjudicated by an order dated 27th February, 2004. The second show cause notice, invoking the larger period (December, 2002 to March, 2003) alleged suppression and mis-declaration by the assessee, which was also the allegation in the earlier show cause notice and duly adjudicated. In such a factual backdrop, the Commissioner (Appeals) determined as to whether there was any suppression of facts by the assessee. He disagreed with the adjudicating authority and after referring to all the materials on record, including the RT 12 returns, he held that the department could not have alleged suppression, when all the facts were disclosed in the returns and the assessee specifically claimed that it was not liable to pay any duty. There are figures on record from which appropriate inference could have been drawn by the Revenue. It is, therefore, the department''s obligation to investigate and for that purpose, it possessed the requisite powers. If the department fails in that duty, it could not turn around and blame the assessee. 5. That is how the Commissioner (Appeals) approached the matter. The tribunal endorsed this approach because it found that the same was not vitiated by any error of law apparent on the face of the record. The tribunal referred to the judgment in the case of Northern Plastic Ltd. vs. Collector of Customs and Central Excise , (1998) 101 ELT 549 (SC). The tribunal endorsed this approach because it found that the same was not vitiated by any error of law apparent on the face of the record. The tribunal referred to the judgment in the case of Northern Plastic Ltd. vs. Collector of Customs and Central Excise , (1998) 101 ELT 549 (SC). The tribunal relied upon it because the principle enshrined therein had application to the case at hand. Meaning thereby, it did not blindly follow this principle. The principle is, when all the facts necessary to be disclosed by the assessee have been disclosed and there cannot be any allegation of suppression, then, the extended period of limitation cannot be invoked. On facts, it found no suppression in this case. That is what the Commissioner (Appeals) also found. It is, therefore, the endorsement of the Commissioner''s finding and conclusion. 6. We do not find any perversity in these concurrent orders. There is no error of law apparent on the face of the record. The appeal raises no substantial question of law. It is, accordingly, dismissed, but without any order as to costs.