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2000 (3) TMI 112 - CEGAT, NEW DELHIExtract: .......tor has no relevance to the proposition under consideration and secondly it is not made part of the show cause notice issued to the assesses. Since it is a question of fact which calls for verification, it cannot be allowed to be canvassed at the second appeal stage. 6. In view of above discussion, the revenue appeal fails and the same is rejected.
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