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2018 (2) TMI 999 - AT - Central ExciseCENVAT credit - input services - Real Estate Service - Commercial Construction Service - change of opinion - extended period of limitation - Held that: - the transactions under dispute are properly recorded in the books of accounts ordinarily maintained in the normal course of business - also, the said transactions were already subjected to previous audit which was done prior to May, 2013. It is evident on the face of record, that it is only after the subsequent audit that the SCN were issued by way of change of opinion. The SCN for the extended period of limitation is not maintainable - appeal allowed - decided in favor of appellant.
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