Mis-declaration and Concealment: confiscation affirmed, transaction value re-determined and mandatory penalty sustained; redemption allowed on payment...
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Interpretation of the General Clauses Act rule excluding the first day and including the last day governs computation of "month" for statutory time-limits under the CGST regime: where an order must be passed by a specified calendar date, the terminal day is included and the day on which a process (show cause notice) is issued is excluded when counting the requisite months. Applying that rule, the three consecutive months prior to the terminal month satisfy the "at least three months" requirement for issuance of a show cause notice, rendering notices issued on or before the excluded initial date within limitation.
Interpretation of the General Clauses Act rule excluding the first day and including the last day governs computation of "month" for statutory time-limits under the CGST regime: where an order must be passed by a specified calendar date, the terminal day is included and the day on which a process (show cause notice) is issued is excluded when counting the requisite months. Applying that rule, the three consecutive months prior to the terminal month satisfy the "at least three months" requirement for issuance of a show cause notice, rendering notices issued on or before the excluded initial date within limitation.
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