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2012 (8) TMI 565 - AT - Service TaxExtended period of limitation - Demand of duty – non-incaution of value of the sale of SIM card in gross taxable value – Held that:- Since the earlier decisions of the Tribunal were in favour of the assessee, it has to be held that there was bona fide doubt about the non inclusion of the cost of SIM card in the value of services. If that be so, no mala fide can be attributable to the appellant so as to invoke the extended period of limitation - demand raised beyond the period of limitation is barred by limitation - no penalty is imposable upon the appellants
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