Extended period of limitation - The fallacious approach adopted...

Extended period of limitation - The fallacious approach adopted by the Appellate Tribunal, though the consideration as to revenue neutrality and exemption under the relevant notifications become irrelevant upon it being noticed that the show-cause notice issued in the year 2008 could not have related to a period of more than one year prior to the date of its issuance since there was no element of deceit or intention on the part of the assessee to evade duty nor had any case in such regard been made out - HC