Tribunal Rules: No Extended Limitation Period or Penalty Under Finance Act 1994 Sections 65(68) & 65(86b.

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....Extended period of limitation - the Tribunal having come to the conclusion that the issue turned upon an interpretation of the provisions of Section 65(68) and Section 65(86b) of the Finance Act 1994, there was no warrant to allow the invocation of the extended period of limitation and to direct the determination of the penalty following the re-quantification of the demand. - SC....