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    <title>2019 (6) TMI 624 - CESTAT NEW DELHI</title>
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    <description>The Tribunal held that the show cause notice was not valid for invoking the extended period of limitation. It found that the charges in question had been properly recorded and disclosed earlier, with no objection raised during a previous audit. The Tribunal deemed the notice as a change of opinion by the Revenue, ruling it invalid. Consequently, the impugned order was set aside, and the appeal was allowed with consequential relief. The decision emphasized that the extended period of limitation cannot be invoked solely based on a change of opinion, especially when transactions were appropriately accounted for and disclosed.</description>
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      <title>2019 (6) TMI 624 - CESTAT NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=381547</link>
      <description>The Tribunal held that the show cause notice was not valid for invoking the extended period of limitation. It found that the charges in question had been properly recorded and disclosed earlier, with no objection raised during a previous audit. The Tribunal deemed the notice as a change of opinion by the Revenue, ruling it invalid. Consequently, the impugned order was set aside, and the appeal was allowed with consequential relief. The decision emphasized that the extended period of limitation cannot be invoked solely based on a change of opinion, especially when transactions were appropriately accounted for and disclosed.</description>
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