Among other things, he contended that issuance of the SCN was arbitrary, unreasonable and patently a perverse one, as it was issued after 12 years. The complaint followed an investigation by

the Directorate of Enforcement in New Delhi, which commenced in 2012, i.e. 9 years ago. He had proactively participated and cooperated in the investigation undertaken by the ED. Given the

substantial lapse of time following the inquiry, the petitioner has conducted himself under the bonafide belief that after due study of the materials obtained during the course of the probe,

the ED had concluded that no action was warranted in the matter. And, he had effected bonafide transfers to third parties in the intervening period and had completely exited from the