Concessional penalty for search-disclosed unreconciled jewellery applies where substantive disclosure conditions are met despite omission from origina...
Extended period of limitation - There is also no denial that show cause notices were issued to the appellant for the same reason as in the present appeal for the immediately prior period (2005- 2011). It does not lie in the mouth of the Department to still allege suppression. Otherwise also the entire dispute appears to be revenue neutral - there appear no revenue consequences. - Thus, extended period is held to have wrongly been invoked by the Department. Show Cause Notice itself gets hit by period of limitation. - AT
Extended period of limitation - There is also no denial that show cause notices were issued to the appellant for the same reason as in the present appeal for the immediately prior period (2005- 2011). It does not lie in the mouth of the Department to still allege suppression. Otherwise also the entire dispute appears to be revenue neutral - there appear no revenue consequences. - Thus, extended period is held to have wrongly been invoked by the Department. Show Cause Notice itself gets hit by period of limitation. - AT
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