Section 73(1) of Finance Act, 1994: Demand Must Adhere to Specified Timeframe, Not Department's Knowledge Date.

The demand u/s 73 (1) of the FA, 1994 has to be issued within the period with reference to relevant date as stipulated in the said Section. There is no provision to determine ‘relevant date’ based on the date of knowledge acquired by the Department - AT .....

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