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    <description>A show cause notice was held time-barred because the extended limitation period could not be invoked without suppression, fraud, or concealment of material facts. The assessee was a registered taxpayer maintaining regular books and filing periodical returns, and the demand was based on information already available from its records. The credit taken on CVD paid through DEPB was treated as a bona fide claim supported by judicial precedent, with no finding that any material return column was left blank or that relevant facts were withheld. The extended period was therefore invalid, and the demand could not be sustained.</description>
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