2019 (10) TMI 169

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..... ven the SCN does not point out to suppression of fact, fraud or mis-statement etc. to fasten the liability of penalty under Section 78. In fact, the alleged activity was observed by the Audit Party from the appellant s ST-3 Returns only and it is not the case of the Revenue that there was gross violation by act of suppression, etc. - the bonafides of the appellant could not be doubted and hence, i .....

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..... on 78. He also points out that the appellant is providing inter alia Manpower Recruitment Supply Agency , Cleaning Service and Renting of Immovable Service etc. It is the case of the Revenue that there was an internal Audit-II Commissionerate, Bangalore, covering the impugned period; that during the audit, it was observed from the appellant s ST-3 Returns that the appellant was also providi .....

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..... nalty under Section 78, is before this Forum. 3. Admittedly, the tax as well as the interest has been paid much before the issuance of SCN; even the SCN does not point out to suppression of fact, fraud or mis-statement etc. to fasten the liability of penalty under Section 78. In fact, the alleged activity was observed by the Audit Party from the appellant s ST-3 Returns only and it .....

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