2019 (3) TMI 1395

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..... Adv. For the Respondent Shri B. Balamurugan, AC (AR) ORDER Per Bench: The above application for rectification of mistake has been filed by the appellants seeking to rectify the mistake in Final Order No.40508/2018, dated 27.02.2018. 2. On behalf of the applicant, the learned counsel Shri T. Ramesh submitted that the above appeal was taken up for disposal along with other batch of appeals .....

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..... e Shri B. Balamurugan, AC (AR) opposed the application. He submitted that there is no error apparent on the face of records that require rectification. That the application is without any merits. 4. Heard both sides. 5. On perusal of the impugned order, we note the fact that the Tribunal in para 3 as well as para 4 had recorded the submissions of the counsel with regard to the issue of limitatio .....

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..... he part of the applicant and equal penalty under section 78 was imposed. The applicant now contends that the said issue with regard to limitation has not been considered by the Tribunal. In fact, the issue whether the incentive received for Amedus CRS Software is liable to service tax was an interpretational one and taking into consideration the arguments of the learned counsel in para 5 that sect .....

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