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    <title>2023 (3) TMI 639 - CESTAT AHMEDABAD</title>
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    <description>Exploration-related activities were held classifiable under Survey and Exploration of Minerals Service rather than the category adopted by the department, because prior decisions and a departmental circular supported that treatment and the legal position on classification had become clearer over time. The extended limitation period was also found inapplicable, as the record showed classification confusion within the department and no established suppression with intent to evade tax. The demand was therefore not sustained on merits or limitation, and the ratio emphasises that extended limitation cannot rest on bona fide classification disputes without deliberate evasion.</description>
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      <description>Exploration-related activities were held classifiable under Survey and Exploration of Minerals Service rather than the category adopted by the department, because prior decisions and a departmental circular supported that treatment and the legal position on classification had become clearer over time. The extended limitation period was also found inapplicable, as the record showed classification confusion within the department and no established suppression with intent to evade tax. The demand was therefore not sustained on merits or limitation, and the ratio emphasises that extended limitation cannot rest on bona fide classification disputes without deliberate evasion.</description>
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