1989 (10) TMI 224

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....had not been issued before making the assessment; and (2) no notice in form ST-65 had been issued before imposing penalty. After hearing learned counsel for the parties and perusing the record of the case, we do not find any merit in either of the two submissions. Before the authorities, the petitioner did not raise any objection regarding the non-service of notice in form ST-17 before it made ....

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....ription of form of notice in form ST-65 is not mandatory, it is directory. In support of the ground learned counsel for the petitioner cited authority of the final court in Ramchandra Keshav Adke v. Govind Joti Chavare reported in AIR 1975 SC 915. We are afraid, this case does not help the learned counsel for the petitioner. In this case the final court was not dealing with the point in issu....