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Extended Limitation Period Justified for Tax Evasion u/s 73(1) Due to Suppression of Facts.

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....Extended period of limitation - penalty - The material facts were unearthed by the Department and hence, non-furnishing of any facts would clearly amount to suppression of acts with an intention to evade tax within the meaning of Section 73(1) ibid. Hence, the Revenue is justified in invoking the larger period of limitation for this activity. So, the demand and penalty in respect of this activity are, therefore, required to be sustained. - AT....