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2019 (9) TMI 178 - CESTAT ALLAHABADTime Limitation - Liability of service tax - Clearing and Forwarding Agent Service - Storage and Warehousing Service - Packing Services’ Goods Transport Agency Service - HELD THAT:- The contentions raised by the appellant relates to the factual verification, which cannot be done at the level of the Tribunal. Extended period of limitation - HELD THAT:- In the absence of any evidence to the contrary indicating any mala fide on the part of the assessee, the extended period of limitation was not available to the Revenue. However, a part of the demand falls within the limitation period and as such, we have not given any findings on merits on the ground of factual verification. The matter remanded to the Original Adjudicating Authority to deal with the merits of the case for the period falling within the limitation and to re-decide the same after taking into consideration the appellant’s contention - appeal allowed by way of remand.
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