2024 (5) TMI 1695

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....the Appellant : None For the Respondent : Shri V.R. Pavan Kumar, AR ORDER [per: R. MURALIDHAR] The Division Bench had agreed on the issue of limitation that extended period of limitation is not available to the Department. However, there was a difference of opinion which is recorded in Para 15 of the Division Bench Order which is as follows: "15. As there is difference of opin....