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of The case involves final assessment of provisional assessments u/s Best Judgement method. Appellant used a formula approved by Department and submitted CA certificate for assessable value. Adjudicating authority verified documents but disregarded CA certificate without reason. Tribunal held CA certificate valid for final assessment. Extended limitation period not applicable as no suppression of facts. Show Cause Notice issued beyond normal period not sustainable. Impugned order set aside, appeal allowed.
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