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    <title>1986 (11) TMI 188 - CEGAT, NEW DELHI</title>
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    <description>Extended limitation under Section 11-A required proof of fraud, collusion, wilful misstatement or suppression of facts, and that proof was not made out on the record. The department relied on common partners and price disparity to say the transactions were not at arm&#039;s length, but it produced no adequate evidence that the disputed product sales were influenced by extraneous consideration or that any specific wrong declaration had been made. As price lists were filed and clarification on related person was sought, suppression or misdeclaration was not established; the extended period could not be invoked and denial of the invoice-value benefit under Notification No. 120/75 was unsustainable.</description>
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    <pubDate>Thu, 13 Nov 1986 00:00:00 +0530</pubDate>
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      <title>1986 (11) TMI 188 - CEGAT, NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=72620</link>
      <description>Extended limitation under Section 11-A required proof of fraud, collusion, wilful misstatement or suppression of facts, and that proof was not made out on the record. The department relied on common partners and price disparity to say the transactions were not at arm&#039;s length, but it produced no adequate evidence that the disputed product sales were influenced by extraneous consideration or that any specific wrong declaration had been made. As price lists were filed and clarification on related person was sought, suppression or misdeclaration was not established; the extended period could not be invoked and denial of the invoice-value benefit under Notification No. 120/75 was unsustainable.</description>
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