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2011 (2) TMI 174 - CESTAT, AHMEDABADTaxable event - Designs, technical know-how etc., which were admittedly prepared by the appellant in Boston, stand transferred by them to IOCL - The taxable event has not occurred in India, inasmuch as the activity of development of technology, technical information and know-how, transfer of design, drawing etc., have taken place in USA - The consumption of such services in India, when admittedly no such service stands provided by the appellant in India, cannot be held to be a taxable event. Demand - Limitation - provisions of section 73 - Any bona fide lapse not to make enquiries about its obligation to pay duty/tax, cannot be made reason for invocation of extended period unless there is evidence to show that such lapse was on account of mala fide intention, and with guilty mind of avoiding payment of tax - There being none in the present case, we are of the view that the demand having been raised beyond the normal period of limitation, is barred by limitation.
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