Extended Limitation cannot be invoked if SCN was issued based on balance sheet

Commissioner of Central TAX Vs ABB Limited (Karnataka High Court)

Undisputed facts of the case are, as recorded in paragraph 6 of the show cause notice, it was issued based on the balance sheet for the year ending 2008. Thus, the contentions of the Revenue that respondents trading activity was not known to the department and that it was learnt based on intelligence report are not tenable.

In Shriram Value Services Pvt. Ltd., the Madras High Court has held

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