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    <title>2015 (12) TMI 1038 - GUJARAT HIGH COURT</title>
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    <description>Additional tax computed as a percentage of tax payable could not be levied on sales wholly exempt under section 49(2) because the underlying tax liability was nil, so the additional tax was also nil. The Tribunal&#039;s view that such tax had to be paid in cash before 3 March 2001 could not stand, because the exemption notification was amended only from that date and the dispute before it concerned liability, not payment mode. Revisional proceedings under section 67 were barred where the Commissioner acted beyond the three-year limitation period, rendering the notices without jurisdiction.</description>
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      <description>Additional tax computed as a percentage of tax payable could not be levied on sales wholly exempt under section 49(2) because the underlying tax liability was nil, so the additional tax was also nil. The Tribunal&#039;s view that such tax had to be paid in cash before 3 March 2001 could not stand, because the exemption notification was amended only from that date and the dispute before it concerned liability, not payment mode. Revisional proceedings under section 67 were barred where the Commissioner acted beyond the three-year limitation period, rendering the notices without jurisdiction.</description>
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