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    <title>1997 (1) TMI 276 - CEGAT, MUMBAI</title>
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    <description>Once a show cause notice is held time-barred and that limitation finding is not challenged, the Department cannot later reopen the dispute by arguing the merits. The prior adjudication had already withdrawn the notice on limitation, and that determination attained finality. Because the bar of limitation remained unassailed, a merits-based challenge could not displace the earlier final finding or cure the time-bar defect. The Department was therefore precluded from contesting the matter on merits after limitation had become final against it.</description>
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    <pubDate>Tue, 07 Jan 1997 00:00:00 +0530</pubDate>
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      <title>1997 (1) TMI 276 - CEGAT, MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=86727</link>
      <description>Once a show cause notice is held time-barred and that limitation finding is not challenged, the Department cannot later reopen the dispute by arguing the merits. The prior adjudication had already withdrawn the notice on limitation, and that determination attained finality. Because the bar of limitation remained unassailed, a merits-based challenge could not displace the earlier final finding or cure the time-bar defect. The Department was therefore precluded from contesting the matter on merits after limitation had become final against it.</description>
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      <pubDate>Tue, 07 Jan 1997 00:00:00 +0530</pubDate>
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