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of Validity of SCN - Admittedly, no such SCN is found in the file. Once, there is no such SCN found in the file, then, there was no sanction in law to make an Order-in-Original, particularly, after the period of nearly 18 years from the date of filing of the Bill of Entry and 12 ½ years from the date of the assessment, as contemplated by Sub-sections (1) and (2) of Section 18. - HC
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