TMI Blog2018 (2) TMI 999X X X X Extracts X X X X X X X X Extracts X X X X ..... 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. - E/70250/2016-EX[SM] ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... vat credit on the aforementioned services and the same appeared to be not admissible. Accordingly, show cause notice dated 28/04/2014 was issued invoking the extended period of limitation, alleging that these facts came to notice only when audit was conducted for the period May, 2013 to May 2014. 3. Heard the parties. 4. Having considered the rival contentions, I find that from the very face ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... , that it is only after the subsequent audit that the show cause notices were issued by way of change of opinion. Accordingly, I hold that the show cause notice for the extended period of limitation is not maintainable. Thus, the appeal is allowed and the impugned order is set aside. The appellant shall be entitled to consequential benefits, in accordance with law. (Dictated in Court) - - T ..... X X X X Extracts X X X X X X X X Extracts X X X X
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