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1987 (7) TMI 241 - CEGAT, NEW DELHIExtract: .......e been a suppression since the department themselves had assessed these items (under Item 68). They only changed their mind later and, as it happened, correctly, to assess them under Item 33-C. There is neither fraud nor suppression, and the period of demand, therefore, cannot run for more than six months from the date the demand notice was issued.
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