2024 (9) TMI 461

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..... of limitation involves jurisdiction of the authorities, then, the findings, though mixed in character, raise a substantial question of law - it was held by the High Court that ' The attempt of the Assessee is nothing but to seek a reappreciation and reappraisal of a factual finding with an intention to delay meeting the demand. The attempt of this nature does not result in the Appeal being ent .....

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