TMI Blog2019 (6) TMI 687X X X X Extracts X X X X X X X X Extracts X X X X ..... September 2006, i.e., just before the period for which the demand has been raised. Thus, the Department was at all times during the period for which the demand has been raised were aware of the declaration made by the respondent that they will not be liable to pay the service tax on 41% levy collected from the contractee and paid over to the Grocerty Market and Shop Board. The finding of fact a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ified in holding that the extended period of limitation under Section 78(1) of the Finance Act, 1994 would not apply ? 3] During the period January 2007 to November 2009, the respondent who was registered under the category of Manpower Recruitment or Supply Agency Services had provided taxable service to various clients. The respondent paid service tax payable on the wages paid to its ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ned order of the Tribunal inter alia records the fact that in September 2006, i.e. prior to commencement of the period for which the demand is being made, the respondent had informed the Department that it is not obliged to pay service tax on additional 41% collected from the contractee to be paid over to Grocery and Markets and Shop Board. Thus, the impugned order holds that in the above context, ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n 19th September 2006, i.e., just before the period for which the demand has been raised. Thus, the Department was at all times during the period for which the demand has been raised were aware of the declaration made by the respondent that they will not be liable to pay the service tax on 41% levy collected from the contractee and paid over to the Grocerty Market and Shop Board. In these circumst ..... X X X X Extracts X X X X X X X X Extracts X X X X
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