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    <title>2021 (7) TMI 131 - CESTAT CHANDIGARH</title>
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    <description>Extended limitation was found unsustainable where denial of credit arose on an issue on which similarly placed assessees had already been granted credit and the Revenue had taken divergent stands. The discussion treats the lack of uniformity in the Revenue&#039;s position, including its own appeals in comparable matters, as the decisive factor against invocation of the extended period. The denial of credit was therefore treated as barred by limitation, and the extended period of limitation as inapplicable.</description>
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      <description>Extended limitation was found unsustainable where denial of credit arose on an issue on which similarly placed assessees had already been granted credit and the Revenue had taken divergent stands. The discussion treats the lack of uniformity in the Revenue&#039;s position, including its own appeals in comparable matters, as the decisive factor against invocation of the extended period. The denial of credit was therefore treated as barred by limitation, and the extended period of limitation as inapplicable.</description>
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