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Second Show Cause Notice Invalid for Interest Demand u/s 28 AA Due to Improper Extended Limitation Period Use.
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....Validity of second SCN - invocation of Extended period of Limitation - it is found that the amount of interest under Section 28 AA demanded in the earlier show cause notice also, and the same was confirmed in the adjudication proceedings, which is presently subjudice before the Hon’ble Rajasthan High Court. Thus, in the present show cause notice, which is mainly for the demand of interest under Section 28 AA and also for a small amount of short tax paid for the same period, is bad for invocation of extended period of limitation. - AT....