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Issues: Whether credit taken within one year under Rule 57AA was barred by limitation or was within a reasonable period.
Analysis: The dispute turned on whether the time limit for taking credit had to be read as six months or, after amendment of the proviso to Section 11A, as one year. The Tribunal noted that earlier decisions treating six months as the reasonable period were rendered when the recovery period under Section 11A was still six months. For the relevant period, Section 11A had been amended to extend the recovery period to one year, and the same logic was applied to conclude that credit taken within one year satisfied the reasonable period requirement.
Conclusion: Credit taken within one year was held to be within a reasonable period, and the Revenue's challenge failed.