Service Tax Audit Precludes Extended Limitation for DGGI Investigation; No Suppression Alleged During Audit Period.

Extended period of limitation - Since there had been service tax audit conducted prior to the DGGI investigation covering the period under dispute, the suppression cannot be alleged by the department for income reconciliation of books and ST 3 returns as no such allegation was raised during department audit. Hence, extended period of limitation also cannot be invoked to raise any demand. - AT .....

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