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Extended Limitation Period Can Be Invoked If New, Undisclosed Grounds Emerge During Routine Audits, Says Authority.

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....Extended period of limitation - Surprisingly, the adjudicating authority has made an observation that visit of officers for routine checkup and audit does not debar the invocation of larger period if new ground comes to law, which was not revealed by the assessee to the department. However, the adjudicating authority has not substantiated as to what new ground had come to light pursuant to audit.....