Court Rules Reliance on CERA Report for Extending Limitation Period Illegal; Independent Assessment Required by Commissioner.

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....Challenge to the show cause notice invoking extended period of limitation - The Commissioner has not properly and independently applied his mind to the question of whether the conditions for invoking the extended period of limitation existed, but has acted mechanically, swayed by the report of the CERA team, which in itself appears to be illegal and unsustainable. - HC....