Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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Extended period of limitation - They were under the bonafide belief that the processes undertaken by them did not amount to manufacture and accordingly cleared the goods to the raw material supplier on collection of ‘job charges’ only. Thus there is no evidence available on record to establish that the Appellant has suppressed the information of manufacture of dutiable goods with an intention to evade payment of duty. - AT
Extended period of limitation - They were under the bonafide belief that the processes undertaken by them did not amount to manufacture and accordingly cleared the goods to the raw material supplier on collection of ‘job charges’ only. Thus there is no evidence available on record to establish that the Appellant has suppressed the information of manufacture of dutiable goods with an intention to evade payment of duty. - AT
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