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    <title>2025 (3) TMI 279 - MADRAS HIGH COURT</title>
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    <description>The HC quashed a SCN issued by the appellant on grounds it exceeded the 90-day limitation period prescribed in regulations. While a prior SCN dated 02.12.2014 from Additional Director General, Directorate of Revenue Intelligence could qualify as an offence report, there was no evidence on record that the respondent was aware of or received this notice. Unlike precedent cases where notice copies were specifically marked to relevant authorities, no such marking was demonstrated here. The HC concluded that without proof of knowledge or receipt of the earlier SCN, the limitation period violation stood, and allowed the appeal quashing the impugned SCN.</description>
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      <link>https://www.taxtmi.com/caselaws?id=766894</link>
      <description>The HC quashed a SCN issued by the appellant on grounds it exceeded the 90-day limitation period prescribed in regulations. While a prior SCN dated 02.12.2014 from Additional Director General, Directorate of Revenue Intelligence could qualify as an offence report, there was no evidence on record that the respondent was aware of or received this notice. Unlike precedent cases where notice copies were specifically marked to relevant authorities, no such marking was demonstrated here. The HC concluded that without proof of knowledge or receipt of the earlier SCN, the limitation period violation stood, and allowed the appeal quashing the impugned SCN.</description>
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