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      <description>Limitation was treated as a question of law that could be raised at the appellate stage even though it had not been urged before the lower authorities. The record suggested that the demand may have been raised beyond the five-year period, but the underlying facts required verification by the adjudicating authority. The matter was therefore remitted for fresh examination of whether the demand was time-barred, with a direction to afford the assessee an opportunity of hearing before passing a new order.</description>
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