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of Non-compliance with the requirement of holding the mandatory pre-SCN consultation - In effect what appears to have transpired pursuant to the summons issued was a ‘consultation’ where the documents produced by the Petitioner/employees of the Petitioner were examined and questions were posed to the notices to explain many aspects of such documents. - In the considered view of the Court, the requirement of there having to be a ‘consultation’ in terms of paragraph 5.0 of the Master Circular stands satisfied in the present case - HC
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