Show Cause Notice Invalid: Proceedings Closed u/s 73(3) of Finance Act 1994, No Penalties Imposed.

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....Validity of show cause notice - extended period of limitation - Whether the ingredients for resort to proviso to section 73(1) of FA, 1994 are present to obviate the contention that section 73(3) of FA, 1994 should have been resorted to for closing the matter? - This is a fit case of closure of the proceedings u/s 73(3) of FA, 1994, without any of the penalties - AT....