TMI Blog2018 (3) TMI 1432X X X X Extracts X X X X X X X X Extracts X X X X ..... y because the credit period was spread over beyond the normal limitation, the Revenue took action of imposing penalty. There is a strong case for the appellant to have a reasonable cause of non-reversal of such disputed credit in time - penalty set aside - appeal allowed - decided in favor of appellant. - Service Tax Appeal No.51966/2017 - A/51031/2018 - Dated:- 19-3-2018 - Mr. B. Ravichandr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... able to the appellant due to non-maintenance of these separate accounts. The lower authorities confirmed reversal of ₹ 13,95,406/- and imposed penalty of equivalent amount under Rule 15 of CCR, 2004 read with Section 78 of the Finance Act, 1994. 2. Ld. Counsel for the appellant submitted that trading as a deemed exempted service was introduced as a concept in the Service Tax Rules only w. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ion was created by law only w.e.f. 1.4.2011. Such being the case, he submits that there could be no ground for imposition of penalty. 5. Ld. AR reiterated the findings of the lower authorities and submitted that though the amendment was brought in 1.4.2011, the appellant did not follow the procedure even upto September, 2011. As such, he supported the findings of the lower authorities. 6. Af ..... X X X X Extracts X X X X X X X X Extracts X X X X
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