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2023 (10) TMI 500 - AT - Service TaxInvocation of Extended period of Limitation - SCN issued by way of change of opinion - short payment of service tax - HELD THAT:- The Revenue had adequate notice of the affairs of the appellant, as they were registered with the Department and were filing regular returns. Further, there was audit by Revenue during Feb., 2016 and no such objection was raised. Further, upon requisition by the Revenue, the appellant have filed the requisitioned documents like copy of the IT Return, Form 26 AS, Balance Sheet, etc. during June, 2016, but thereafter, Revenue slept over the matter. Apparently the show cause notice is issued by way of change of opinion. The extended period of limitation is not invokable in the facts and circumstances - Appeal allowed.
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