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1998 (3) TMI 380 - CEGAT, NEW DELHIExtract: .......uo and had held that for the longer period to apply, the term must be qualified by the immediately preceding word ldquo wilful rdquo . Since the preceding words are omitted in the Show Cause notice, the Collector was quite correct in holding that the extended period was not invokable. For the same reason, this application must fail and is rejected.
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