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1997 (1) TMI 286 - CEGAT, NEW DELHIExtract: .......y time. Reopening the proceedings by the Collector by issue of memorandum dated 20-1-1988 is beyond the jurisdiction and not sustainable in law. We upheld the assessee rsquo s contention that there is no suppression of facts or mis-statement to reopen the proceedings. In that view of the matter, we set aside the impugned order and allow the appeal.
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