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    <description>The demand was treated as prima facie time-barred because the Department had been aware of the taxable activity years before the show cause notice and no specific undisclosed primary facts were identified. On that basis, invocation of the extended period was not supported at the interim stage, and the demand appeared to be barred by limitation. The appellants were therefore granted unconditional waiver of pre-deposit and stay of recovery.</description>
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      <description>The demand was treated as prima facie time-barred because the Department had been aware of the taxable activity years before the show cause notice and no specific undisclosed primary facts were identified. On that basis, invocation of the extended period was not supported at the interim stage, and the demand appeared to be barred by limitation. The appellants were therefore granted unconditional waiver of pre-deposit and stay of recovery.</description>
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