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    <title>2026 (6) TMI 1013 - CESTAT CHENNAI</title>
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    <description>Extended limitation under Section 73(1) of the Finance Act, 1994 requires suppression of facts with intent to evade tax; a mere interpretational dispute is insufficient. The text notes that the assessee-bank was a PSU/scheduled bank under continuous regulatory supervision, its transactions were duly recorded in statutory books, and there was no material showing deliberate omission or mischief. On that basis, the longer limitation period was treated as unavailable, and demands raised on that basis were unsustainable. The appeals of the assessee were allowed on limitation, and the departmental appeals were dismissed.</description>
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      <description>Extended limitation under Section 73(1) of the Finance Act, 1994 requires suppression of facts with intent to evade tax; a mere interpretational dispute is insufficient. The text notes that the assessee-bank was a PSU/scheduled bank under continuous regulatory supervision, its transactions were duly recorded in statutory books, and there was no material showing deliberate omission or mischief. On that basis, the longer limitation period was treated as unavailable, and demands raised on that basis were unsustainable. The appeals of the assessee were allowed on limitation, and the departmental appeals were dismissed.</description>
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