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    <title>2024 (11) TMI 1602 - APPELLATE TRIBUNAL UNDER SAFEMA, NEW DELHI</title>
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    <description>Where no statutory limitation is prescribed, enforcement proceedings must still begin within a reasonable time, judged on the facts. Applying the principle in Citibank, the tribunal held that a decade-long delay between the 1992 transaction and the 2002 show-cause notice was not justified by intermittent statements or later call letters, and the proceedings were vitiated. It also held that adjudication cannot stand where relied upon documents are not supplied and the noticee is denied an effective hearing, including meaningful defence and cross-examination. On the facts, non-disclosure was established, so the adjudication was unsustainable for breach of natural justice and was set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=467401</link>
      <description>Where no statutory limitation is prescribed, enforcement proceedings must still begin within a reasonable time, judged on the facts. Applying the principle in Citibank, the tribunal held that a decade-long delay between the 1992 transaction and the 2002 show-cause notice was not justified by intermittent statements or later call letters, and the proceedings were vitiated. It also held that adjudication cannot stand where relied upon documents are not supplied and the noticee is denied an effective hearing, including meaningful defence and cross-examination. On the facts, non-disclosure was established, so the adjudication was unsustainable for breach of natural justice and was set aside.</description>
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