2012 (2) TMI 298

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....nst the first Appellate order submitting that the contract which comprised various sub-activities and called for taxation under different clauses of taxable entries under Section 65(105) of the Finance Act, 1994, on the misconception that the entire contract being turnkey is not subjected to vivisection allowed appeal of Assessee.   2. Learned Counsel for the respondents submits that vivisec....

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....ls in between two periods from 1.4.2001 to 31.3.2003 and 10.9.2004 to 30.9.2006 which were subject matter of show cause notices dated 8.4.2004 and 19.4.06. When the material facts were known to the Department since BHEL is a giant sector and its activities are scrutinized by Authorities, the facts and circumstances did not give rise to suppression of facts for taxing under Finance Act, 2004. He re....