Allegations of fraud in revenue case lack specific claims in notice and audit order; oral assertions unsupported.

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....Fraud in depriving the respondents of their due revenue or not - When the impugned notice did not allege fraud and no such finding of fraud being discernible in the order of audit, it is not open to the respondents to make such sweeping allegation of fraud in the oral hearing which is not backed up by adequate pleadings. - HC....