Section 11A Limitation Period Not Applicable: No Evidence of Doubt on Assessee's Bona Fides, No Penalties or Interest Imposed.

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....Extended period of limitation - There is nothing to indicate that the appellant revenue doubted the bona fides of the respondent assessee. In such circumstances extended period of limitation could never have been invoked in the assessee’s case. Thus, if Section 11A of the Act could not have been invoked, the question of imposing penalty or levying interest also does not arise. - HC....