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2nd SCN issued despite withdrawal of 1st SCN for different amount permissible if within limitation, no new grounds allowed in review.
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Second SCN issued pending adjudication of first SCN subsequently withdrawn - jurisdiction of first SCN challenged - withdrawal of first SCN after issuance of second SCN for differential amount not identical - second SCN within limitation period u/s 28(4) - opportunity to submit reply before authority - no error apparent - review to reagitate grounds already considered impermissible - review to raise new grounds not argued earlier impermissible - review dismissed.