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    <title>1996 (9) TMI 263 - CEGAT, MUMBAI</title>
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    <description>A reference to the High Court was considered appropriate on whether the extended limitation period under Rule 56A(5) could sustain a demand when the show cause notice contained no specific allegation of suppression or fraud. The notice was found to lack the averments needed to invoke the longer period, and the question was treated as a point of law arising from the record. The Tribunal also noted that the issue was not barred merely because it had not been argued earlier at the time of disposal of the appeal, and it framed the question for the High Court.</description>
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