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    <title>2024 (3) TMI 279 - CESTAT AHMEDABAD</title>
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    <description>A duty demand relating to transactions from October to December 2000 was held time-barred because the extended limitation period was invoked only after audit objections raised years later, and the record did not show suppression of facts or intent to evade duty. The absence of cogent material supporting mala fide conduct meant the department could not justify extending limitation, especially where it had an opportunity to verify the transactions within the normal period. The proposed penalty was also dropped, reinforcing that the demand could not be sustained as within limitation. The finding was in favour of the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=450498</link>
      <description>A duty demand relating to transactions from October to December 2000 was held time-barred because the extended limitation period was invoked only after audit objections raised years later, and the record did not show suppression of facts or intent to evade duty. The absence of cogent material supporting mala fide conduct meant the department could not justify extending limitation, especially where it had an opportunity to verify the transactions within the normal period. The proposed penalty was also dropped, reinforcing that the demand could not be sustained as within limitation. The finding was in favour of the assessee.</description>
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