Limitation on show cause notice: notice issued after investigation was complete was held time-barred and unsustainable.

A show cause notice issued after officers had already visited the premises and completed the investigation was held to be barred by limitation. The demand was based on documents and statements recovered during that visit, and no further investigation was shown thereafter. On that footing, the Tribunal followed its earlier view that a notice issued beyond the permissible period, once the material facts were already gathered, cannot be sustained. The notice was therefore time-barred and the demand could not be upheld.

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Issues: Whether the show cause notice issued after the officers' visit and completion of investigation was barred by limitation.

Analysis: The demand was founded on documents and statements recovered during the visit of the officers, and no further investigation was shown after that date. The notice was issued after the permissible period, and the Tribunal followed its earlier view that a notice issued beyond the limitation period, after the material facts were already gathered, cannot be sustained.

Conclusion: The show cause notice was time-barred and the demand could not be upheld.

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