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2022 (4) TMI 1572 - AT - Service TaxRectification of mistake filed by the applicant - apparent error in the order or not - Appellant submits that the remand may be made open for the issue of limitation as well as penalty for re-considering not only on Revenue neutrality but otherwise also - HELD THAT:- It is found that in Para 4.3, though the matter was remanded on the issue of limitation as well as imposition of penalty but it is confined to the point of Revenue neutrality. However, considering the other facts of the case, it would be proper that the issue of limitation as well as imposition of penalty should be reconsidered not only limited to revenue neutrality but on the basis of other facts also. Therefore, the issue of limitation as well as imposition of penalty needs to be reconsidered as open remand. The Tribunal order dated 24.05.2021 stands rectified to the above extent. ROM application is allowed.
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