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1999 (1) TMI 95 - CEGAT, MUMBAIExtract: .......the view that facts found by the Collector cannot be questioned as there is no appeal filed by the department against such a finding. Hence, plea of invoking of larger period cannot be upheld. We are, therefore, of the view that the department has not made out any case. Hence, the appeal is allowed with consequential relief if any permitted by law.
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