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Show Cause Notice Validity Questioned: Issued After Five Years, Section 11D Observations Incorrect, Reasonable Time Required.

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....Validity of SCN - the SCN was issued after a period of 5 years - The observations of adjudicating authority on Section 11D is not correct as Section 11D does not provide any rigid time limit. However, show cause notice under Section 11D has to be issued within reasonable period.....