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    <title>2007 (2) TMI 574 - CESTAT, AHMEDABAD</title>
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    <description>Extended period of limitation could not be invoked where the Revenue knew the relevant facts and the assessee acted under a bona fide belief regarding eligibility to Notification No. 108/95-C.E. The exemption was denied because the project was financed by Japan Bank for International Cooperation, which was not treated as a notified international organization, but the show cause notice still covered a period beyond the normal limitation period. As there was no suppression or misstatement, and similar certificates had been issued in comparable matters, the demand was held time-barred and the impugned order was set aside.</description>
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      <description>Extended period of limitation could not be invoked where the Revenue knew the relevant facts and the assessee acted under a bona fide belief regarding eligibility to Notification No. 108/95-C.E. The exemption was denied because the project was financed by Japan Bank for International Cooperation, which was not treated as a notified international organization, but the show cause notice still covered a period beyond the normal limitation period. As there was no suppression or misstatement, and similar certificates had been issued in comparable matters, the demand was held time-barred and the impugned order was set aside.</description>
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