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1999 (2) TMI 206 - CEGAT, CALCUTTAExtract: ....... the invocation of longer period on the basis of collusion between the appellants and the Assistant Collector is not available to the Department. On this ground alone, without expressing any opinion on the merits of the case, we set aside the impugned order on the point of limitation and allow the appeal with consequential relief to the appellants.
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