Tax Case Limitation: Department Must Prove Suppression of Facts; Mere Exemption Claim Isn't Suppression by Assessee.

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....Extended period of limitation - suppression of facts or not - The belief of an assessee may be right or wrong but it is incumbent on the department to ascertain the correctness of the eligibility of the exemption notification. Therefore, by declaring the goods under exemption there cannot be a charge of suppression of fact on the part of the appellant. - AT....