2004 (2) TMI 405

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..... llant. Shri A.K. Mondal, SDR, for the Respondent. [Order per : Archana Wadhwa, Member (J)]. All the three stay petitions are being taken up together as the issue involved is identical in all the three cases. 2. We have heard Shri S.K. Bagaria, ld. Sr. Adv. for the appellant and Shri A.K. Mondal, ld. SDR for the Revenue. 3. We find that the in two appeals i.e. Appeal Nos. 836 and .....

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..... this mandatory requirement of law cannot be done away with by treating each and every communication as a show cause notice. Inasmuch as admittedly the show cause notice was issued after a period of five years from the relevant date, we are of the prima facie view that the demand is barred by limitation. 4. The period involved in Appeal No. 835/2002 is from April 1994 to June 1996 and from April .....

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