2004 (5) TMI 440

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....e and C.M. Ghorawat, Advocate, for the Appellant. Shri Rajen Mohapatra, Advocate, for the Respondent. [Order per : Archana Wadhwa, Member (J)]. - Shri S.K. Bagaria, ld. Sr. Adv. appearing for the appellant has argued on the point of limitation reserving his right to contest the case on merits, in case the decision on the point of limitation goes against him. 2. Arguing on the poin....

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....cts as present in that case and no new fact should be allowed to be introduced at the appeal stage, he referred to various decisions and judgments. 3. Countering the arguments Shri Rajen Mohapatra, ld. adv. appearing for the Revenue submits that though the Commissioner has invoked the longer period of limitation, without appreciating the fact that the assessments were provisional, the fact....