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Extended Limitation Period Upheld for Misdeclaration; Lack of Proof on Advance Return and Unsupported Awareness Claim.
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....Extended period of limitation - misdeclaration or not - the appellant has made no effort to provide any documents to evidence the return of the advance amount - The contention that an earlier show cause notice was issued and the information was in the knowledge of the department is also not evidenced by the records - extended period rightly invoked. - AT....