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    <title>2026 (4) TMI 305 - CESTAT KOLKATA</title>
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    <description>Where the Department had already initiated proceedings on the same facts for an earlier period, a later notice for the subsequent period could not validly invoke the extended period of limitation on the basis of suppression. The prior notice showed that the relevant facts were already within departmental knowledge, so the same factual foundation could not support a fresh allegation of suppression for the later period. On that basis, the demand was treated as time-barred, and the connected interest and penalties were also set aside.</description>
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      <description>Where the Department had already initiated proceedings on the same facts for an earlier period, a later notice for the subsequent period could not validly invoke the extended period of limitation on the basis of suppression. The prior notice showed that the relevant facts were already within departmental knowledge, so the same factual foundation could not support a fresh allegation of suppression for the later period. On that basis, the demand was treated as time-barred, and the connected interest and penalties were also set aside.</description>
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