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HC determined that invoking extended limitation period under First Proviso to Section 73(1) of Finance Act 1994 was unjustified. Following P&B Pharmaceuticals and L&T precedents, court held that when relevant facts were previously disclosed to authorities through earlier notices, allegations of fraud, collusion, willful misstatement or suppression are unsustainable. Mere statutory language reproduction cannot justify extended limitation without substantive proof of willful suppression. Since assessee's position was known from prior proceedings and no new material evidenced deliberate concealment, the show cause notice was quashed for failing to establish grounds for extending limitation period under Section 73(1).
HC determined that invoking extended limitation period under First Proviso to Section 73(1) of Finance Act 1994 was unjustified. Following P&B Pharmaceuticals and L&T precedents, court held that when relevant facts were previously disclosed to authorities through earlier notices, allegations of fraud, collusion, willful misstatement or suppression are unsustainable. Mere statutory language reproduction cannot justify extended limitation without substantive proof of willful suppression. Since assessee's position was known from prior proceedings and no new material evidenced deliberate concealment, the show cause notice was quashed for failing to establish grounds for extending limitation period under Section 73(1).
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