scn can not issue for 5 years

[jagathjeevan guntu]

can a SCN issue for 5 years report if an audit completed every year

AI Summary

Limitation for show-cause notices: annual audits and prior disclosure can bar invoking extended limitation periods.
Issuance of a show-cause notice for an extended past period depends on whether there was suppression, misrepresentation or fraud; if annual audits or prior written disclosure put the department on notice of the activity, the extended limitation cannot be invoked and the department is restricted to the ordinary limitation period measured from the relevant date.