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Exemption in Notification 108/95 doesn't cover JBIC projects; demands after one year and penalties u/s 11AC unsustainable.

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....Exemption under Notification 108/95 is not available to the project financed by JBIC but demand beyond the period of one year from the date of show-cause notice are not sustainable and penalties under Section 11AC on the assessee firm and penalty on GM of the assessee firm is also not sustainable. .... - AT....