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    <title>Time limit for issuance of audit observations in form ADT-02</title>
    <link>https://www.taxtmi.com/forum/issue?id=120318</link>
    <description>An audit report in Form ADT-02 may be contested as time-barred, but the statutory explanation defining commencement of audit (the later of when records called for are made available or when audit is actually instituted at the place of business) gives the department scope to argue that audit completion was within time. Audit memoranda and ADT-02 are distinct: the former is a preliminary opportunity to settle objections, while issuance of ADT-02 triggers adjudicatory proceedings; taxpayers should reply to ADT-02 and raise both time-bar and substantive defences.</description>
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    <pubDate>Sat, 02 Aug 2025 16:51:08 +0530</pubDate>
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      <title>Time limit for issuance of audit observations in form ADT-02</title>
      <link>https://www.taxtmi.com/forum/issue?id=120318</link>
      <description>An audit report in Form ADT-02 may be contested as time-barred, but the statutory explanation defining commencement of audit (the later of when records called for are made available or when audit is actually instituted at the place of business) gives the department scope to argue that audit completion was within time. Audit memoranda and ADT-02 are distinct: the former is a preliminary opportunity to settle objections, while issuance of ADT-02 triggers adjudicatory proceedings; taxpayers should reply to ADT-02 and raise both time-bar and substantive defences.</description>
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      <pubDate>Sat, 02 Aug 2025 16:51:08 +0530</pubDate>
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