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of Invocation of extended period of Limitation - inclusion of Product Development Charges (PDC) received in the value of the goods sold - Such PDC receipts have been properly accounted for and duly disclosed since 2007-2008 and audited by the earlier audit team and no such objection was taken at that time - thus SCN pursuant to the subsequent audit, is only by way of change of opinion - SCN not maintainable
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