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2018 (7) TMI 1117 - AT - Service TaxExtended period of Limitation - denial of CENVAT Credit - plethora of litigation existed between the assessee and the Revenue - Whether the learned Commissioner have rightly held that the extended period of limitation is available in the facts and circumstances? Held that:- It is an admitted fact that all the transactions are properly recorded in the books of accounts ordinarily maintained by the appellant assessee - Further, from the facts on record which are not disputed, it is found that the proposal to deny Cenvat Credit is by way of change of opinion, as admittedly the appellant assessee was registered with the Department and had filed regular returns and maintain proper records. The extended period of limitation is not invocable - demand set aside - appeal allowed - decided in favor of appellant.
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