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1980 (7) TMI 129 - ITAT CHANDIGARHExtract: .......e under s. 17 and the satisfaction on the basis of the information has to be prior to the issue of the notice. 8. We, are, therefore, convinced that the WTO acted without jurisdiction. It was merely a change of opinion and his proceedings were without legal authority. The orders of the authorities below are, therefore, cancelled. 9. Appeal allowed.
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