Revenue's Extended Limitation Period Challenged: No Evidence of Suppression Found Post-Audit, Show Cause Notice Questioned.

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....Extended period of limitation - Except mentioning in the show cause notice that there has been suppression of facts, no positive act committed by the appellant has been put forth by the revenue to allege suppression of facts in the impugned cases. The detection is subsequent to the audit - SCN was not required to be issued.....