TMI Blog2019 (2) TMI 313X X X X Extracts X X X X X X X X Extracts X X X X ..... stand confirmed by invoking the longer period - Held that:- The appellant were duly registered with the department and were filing the ST-3 returns by showing payment of Service Tax on the value of the services as indicated in the contracts entered by them with the said Public Sector Undertaking. The appellant was entertaining a bona fide belief and there was no mala fide on their part so as to ju ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... repair and maintenance services. As per the contract entered into between the two, all the terms of contract indicated the value of services and the value of the goods to be used in the said services. Accordingly the appellant discharged their Service Tax liability on the value of the services indicated in the said contracts. 2. Revenue, by entertaining a view that the appellant has not been ab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 06/07 to 2010/11 and the show cause notice stands issued on 04.10.2011. He submits that that the services were being provided to a Public Sector Undertaking under a contract and inasmuch as the said contract bifurcated the value of the services as also the value of the goods to be used in the said services, on percentage basis, they adopted the assessable value of the services in terms of the cont ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rdingly we hold that extended period is not available to the Revenue. However, as a part of demand falls within the limitation period we direct the adjudicating authority to re-quantify the demands against all the appellants for which purpose, the matter is remanded to him. 5. As we have already concluded that there was no mala fide on the part of the assesses we find no reasons to uphold the p ..... X X X X Extracts X X X X X X X X Extracts X X X X
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