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    <title>2025 (7) TMI 840 - CESTAT CHANDIGARH</title>
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    <description>Extended limitation cannot be invoked merely because a later audit detects transactions when an earlier audit and show cause notice had already covered an overlapping period without raising the same issues, and no independent material of suppression or misdeclaration was shown; the extended period was therefore unsustainable. The normal-period demand and related CENVAT credit dispute required fresh adjudication because the authority had not addressed the assessees&#039; specific submissions on taxability of lease holder receipts, infrastructure provider receipts, channel placement and carriage receipts, or installation, repair and maintenance charges, and the credit claim was rejected without proper verification of supporting documents. Penalties were set aside and the remaining issues were remanded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=774772</link>
      <description>Extended limitation cannot be invoked merely because a later audit detects transactions when an earlier audit and show cause notice had already covered an overlapping period without raising the same issues, and no independent material of suppression or misdeclaration was shown; the extended period was therefore unsustainable. The normal-period demand and related CENVAT credit dispute required fresh adjudication because the authority had not addressed the assessees&#039; specific submissions on taxability of lease holder receipts, infrastructure provider receipts, channel placement and carriage receipts, or installation, repair and maintenance charges, and the credit claim was rejected without proper verification of supporting documents. Penalties were set aside and the remaining issues were remanded.</description>
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