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2000 (6) TMI 669 - CEGAT, MUMBAIExtract: .......ould have been known to the department. Therefore, it is difficult to resist the prima facie conclusion that the department would have been aware of the facts. 7. emsp The notice therefore would be prima facie barred by limitation. Accordingly, we waive deposit of the duty and penalty imposed on the assessee and its manager and stay their recovery.
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