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2018 (7) TMI 23 - AT - Service TaxExtended period of limitation - Banking and Other Financial Services - upfront fee paid on reverse charge basis - Held that:- During this very period, the issue of taxability on such payment made to foreign service provider was mired in litigation - the appellant cannot be charged with having suppressed information or having indulged in misstatement or fraud with intent to evade payment of tax liability. Also, even during the investigation stage and before issue of SCN appellants have paid up the tax liability on 28.11.2007. Extended period of limitation cannot be invoked - appeal allowed on the ground of limitation.
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