Limitation Period Bars Tax Reassessment: No Evidence of Intentional Suppression Invalidates Extended Notices Under Section 73(1)

CESTAT allowed the appeals, invalidating the show cause notices issued beyond the statutory limitation period. The tribunal found no substantive evidence of intentional suppression of facts or tax evasion. The department could not justify extending the limitation period since prior notices had been issued and the financial documents were publicly available. The tribunal concluded that the Commissioner (Appeals) orders were incorrectly passed, particularly regarding the extended limitation under section 73(1) of the Finance Act. Consequently, the appeals were allowed, setting aside the previous orders and providing consequential relief to the appellant. .....

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