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    <title>2000 (11) TMI 363 - CEGAT, CHENNAI</title>
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    <description>A remand confined only to penalty was found inadequate where the challenge went to the very basis of penalty invocation, including the impact of a time-barred demand. The tribunal held that the original authority had to reconsider not just the mechanics of penalty but all objections raised by the appellants, including whether the penalty provision was invocable on the facts and whether limitation affected the demand. The limited remand was therefore modified into an open remand, and the matter was sent back for fresh consideration of the penalty issue on all relevant grounds, with full opportunity to the appellants to contest penalty liability.</description>
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      <title>2000 (11) TMI 363 - CEGAT, CHENNAI</title>
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      <description>A remand confined only to penalty was found inadequate where the challenge went to the very basis of penalty invocation, including the impact of a time-barred demand. The tribunal held that the original authority had to reconsider not just the mechanics of penalty but all objections raised by the appellants, including whether the penalty provision was invocable on the facts and whether limitation affected the demand. The limited remand was therefore modified into an open remand, and the matter was sent back for fresh consideration of the penalty issue on all relevant grounds, with full opportunity to the appellants to contest penalty liability.</description>
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