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    <title>2024 (7) TMI 331 - TELANGANA HIGH COURT</title>
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    <description>Pre-show cause consultation is mandatory in duty-demand matters, but it does not extend to preventive or offence-related notices arising from DRI search and seizure proceedings. Notices framed on tentative findings and inviting objections were treated as prima facie, not final, so they were not struck down as issued with a closed mind. The limitation objection also failed at the writ stage because the notices invoked the extended period on allegations of suppression, wilful misstatement and collusion, and the relevant date issue was left for adjudication after the response. The writ challenge to the show cause notices was therefore declined.</description>
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      <link>https://www.taxtmi.com/caselaws?id=755111</link>
      <description>Pre-show cause consultation is mandatory in duty-demand matters, but it does not extend to preventive or offence-related notices arising from DRI search and seizure proceedings. Notices framed on tentative findings and inviting objections were treated as prima facie, not final, so they were not struck down as issued with a closed mind. The limitation objection also failed at the writ stage because the notices invoked the extended period on allegations of suppression, wilful misstatement and collusion, and the relevant date issue was left for adjudication after the response. The writ challenge to the show cause notices was therefore declined.</description>
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