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    <description>Extended limitation and penalty under Section 78 of the Finance Act, 1994 were held unavailable where the assessee disclosed brokerage activity relating to carbon credit transactions, the department had audit and correspondence records showing awareness of the matter, and tax with interest was paid. The controversy was treated as interpretative rather than involving suppression of facts. On that basis, the earlier precedent that known facts and a bona fide interpretative dispute do not justify extended limitation or penalty was followed, and the Revenue&#039;s challenge failed while the assessee succeeded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=329873</link>
      <description>Extended limitation and penalty under Section 78 of the Finance Act, 1994 were held unavailable where the assessee disclosed brokerage activity relating to carbon credit transactions, the department had audit and correspondence records showing awareness of the matter, and tax with interest was paid. The controversy was treated as interpretative rather than involving suppression of facts. On that basis, the earlier precedent that known facts and a bona fide interpretative dispute do not justify extended limitation or penalty was followed, and the Revenue&#039;s challenge failed while the assessee succeeded.</description>
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