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    <description>Non-reversal of SAD credit on transfer of imported inputs as such was treated as a substantive compliance failure, and the demand, interest and equal penalty were sustained. The Tribunal found that the omission was disclosed in ER-1 returns, but the appellant still refused reversal on limitation grounds, which supported invocation of the extended period. Revenue neutrality was rejected on the facts because availability of credit in another unit did not negate the statutory requirement to reverse the credit or the consequences of non-compliance.</description>
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