TMI Blog1997 (2) TMI 106X X X X Extracts X X X X X X X X Extracts X X X X ..... n the ground of wilful suppression of material facts. The periods involved are 1-7-1980 to 31-12-1980 and 1-1-1981 to 30-6-1981. The first show cause notice issued on 29-8-1981 is clearly beyond the period of six months from the end of the period 1-7-1980 to 31-12-1980. The second notice dated 14-9-1981 is within six months for the period 15-3-1981 to 30-6-1981 but the period of 1-1-1981 to 31-3-1 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... t was filed, was there any wilful suppression? The appellants may have wrongly understood the effect of the amended law granting exemption. That will not make it a case of wilful suppression of facts. In the facts of this case, we are of the view that this is not a case of wilful suppression. The order passed by the Tribunal dated 14-9-1988 must be set aside. The show cause notice dated 29-8-1981 ..... X X X X Extracts X X X X X X X X Extracts X X X X
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