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    <title>2025 (10) TMI 1128 - CESTAT CHENNAI</title>
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    <description>Section 4A valuation for tyres, tubes and flaps as pre-packaged commodities was not sustained because the record showed a long-accepted clearance pattern, prior departmental proceedings on substantially the same facts had been dropped, and no legally relevant change in facts or law was established. The extended period of limitation under Section 11A was also held unavailable because the ingredients of fraud, collusion, wilful misstatement or suppression of facts were not proved; disclosure had been consistent and earlier notices on the same issue had been dropped. The demand and penalties were set aside, the assessee&#039;s appeal was allowed, and the revenue&#039;s appeal was dismissed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=780332</link>
      <description>Section 4A valuation for tyres, tubes and flaps as pre-packaged commodities was not sustained because the record showed a long-accepted clearance pattern, prior departmental proceedings on substantially the same facts had been dropped, and no legally relevant change in facts or law was established. The extended period of limitation under Section 11A was also held unavailable because the ingredients of fraud, collusion, wilful misstatement or suppression of facts were not proved; disclosure had been consistent and earlier notices on the same issue had been dropped. The demand and penalties were set aside, the assessee&#039;s appeal was allowed, and the revenue&#039;s appeal was dismissed.</description>
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