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    <description>The demand and penalties were held to be time-barred because the department had already received the relevant records and explanations during audit, including the basis of clearance and precautions for deemed export transactions. On the facts, there was no established suppression of facts or intent to evade duty, so invocation of the extended period was unsustainable. The impugned order was therefore not sustainable.</description>
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      <description>The demand and penalties were held to be time-barred because the department had already received the relevant records and explanations during audit, including the basis of clearance and precautions for deemed export transactions. On the facts, there was no established suppression of facts or intent to evade duty, so invocation of the extended period was unsustainable. The impugned order was therefore not sustainable.</description>
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