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    <title>2024 (9) TMI 63 - CESTAT AHMEDABAD</title>
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    <description>Extended limitation could not be invoked where the assessee&#039;s treatment of transportation services under GTA was based on a bona fide belief that no consignment note meant the service was not GTA, and the department already had the relevant records from audit, so suppression of facts was not proved. The demand was therefore held time-barred and set aside. As the demand itself failed on limitation and no suppression was established, the penalty had no independent basis and was also quashed.</description>
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      <description>Extended limitation could not be invoked where the assessee&#039;s treatment of transportation services under GTA was based on a bona fide belief that no consignment note meant the service was not GTA, and the department already had the relevant records from audit, so suppression of facts was not proved. The demand was therefore held time-barred and set aside. As the demand itself failed on limitation and no suppression was established, the penalty had no independent basis and was also quashed.</description>
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