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2001 (1) TMI 543 - CEGAT, CHENNAIExtract: ....... of facts must be wilful. The demand therefore is time-barred. 8. emsp In view of the above analysis of facts and the position in law, we are of the view that no case is made out against the appellants either on facts or in law. 9. emsp The appeal, therefore, succeeds and the same is allowed by setting aside the order passed by the lower authority.
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