Extended Limitation Period Inapplicable Due to Regular Statutory Returns; Department Missed Timely Investigation Opportunity.

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....Extended period of limitation - The Show Cause Notice was issued on the basis of audit of records maintained by the Appellant and therefore extended period cannot be invoked by alleging suppression since they are also submitting/filing the statutory returns on a regular basis. The Department was free to further investigate the matter and issue timely Show Cause Notice. - AT....