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Department Can't Re-examine Same Issue u/s 73; Overlapping Timeframe Limits Extended Period of Limitation.

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....Extended period of limitation - The period of time for which the impugned show-cause notice has been issued overlaps with the period of time for which either a proceeding is pending or stands concluded. The department cannot be allowed to revisit the same issue under the garb of exercise of powers u/s 73 of the Act of 1994....