EPCG License Holder Cleared of Fraud Allegations; No Grounds for Extended Limitation Period Show Cause Notice.

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....Since the appellant had categorically informed the department regarding supply of goods under EPCG licence and filed the re-warehousing certificate, the allegation of suppression, fraud, etc. cannot be leveled against the appellant justifying the issuance of show cause notice by invoking the extended period of limitation - AT....