Rejection of application for rectification of mistake - Applicability of extended period of limitation -...

Rejection of application for rectification of mistake - Applicability of extended period of limitation - Tribunal did not consider the issue sought to rectified - Maybe, such a question was not raised by the appellant in the memo of appeal presented before the Tribunal in specific terms but, indisputably, this question remains a jurisdictional question because without existence of the elements specified in the said Proviso to Section 28(1), the show cause notice in question, as issued on 26.09.2..... .....

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