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    <description>In service tax disputes over job-work under Business Auxiliary Service, the extended period of limitation could not be invoked where the matter arose from an interpretational issue and the allegation of suppression was unsupported by reasoned findings of deliberate non-disclosure. The demand stemmed from a CERA audit objection, was not accepted by the department at the relevant stage, and was kept in the call book. On those facts, the show cause notice was held time-barred, and the demand with consequential penalties could not be sustained.</description>
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