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    <title>2025 (3) TMI 496 - CESTAT KOLKATA</title>
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    <description>The demand was held time-barred because the department had already conducted an audit, issued a spot memo and received the assessee&#039;s reply before issuing the show cause notice, so the material supporting the demand was already within the department&#039;s knowledge. On those facts, the extended period of limitation was not available, and the Tribunal followed its earlier view on the same issue. As limitation was dispositive, the Tribunal did not examine the merits of valuation.</description>
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