2015 (7) TMI 428

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....nsel for the rival parties and upon perusal of the impugned order, we frame the following Substantial Questions of Law:- 1. Whether the learned Tribunal is justified in law to hold that the benefit of extended period of five years contemplated by Section 73(1) of Finance Act, 1994 was available to the Department in absence of a finding of fraud, collusion in the judgment impugned? 2.&em....