Time-barred VCES rejection notice fails where only general correspondence supports a roving inquiry and circulars bind the department

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....VCES declaration rejection could not be sustained where the notice proposing rejection was issued beyond the prescribed thirty-day period, including when measured from the circular clarifying its application to declarations already filed. The Tribunal noted that the department's reliance on general correspondence indicated only a roving inquiry, not a proper basis for rejection. As the department was bound by its own circulars, the order upholding rejection of the declaration under the Voluntary Compliance Encouragement Scheme, 2013 was set aside and the appeal was allowed with consequential relief.....