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      <description>Section 73(4B) of the Finance Act, 1994 was held to be directory to the extent qualified by the words &quot;where it is possible to do so&quot;, so the prescribed adjudication period did not operate as an inflexible bar. Where the noticee had received repeated notices, failed to respond earlier, and replied only at the final stage, the subsequent order-in-original passed within about three months was not invalid for delay. The challenge on limitation therefore failed and the appeal was dismissed.</description>
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