Extended Limitation Period for Service Tax Not Applicable Due to Industry-Wide Good Faith Belief in Cenvat Credit Entitlement.

Invocation of Extended period of limitation - respondent had a bonafide belief that it is entitled to Cenvat Credit in respect of all inputs hence there is no occasion of making of declaration in ST-3 Returns would arise - even Commissioner of Service Tax has himself recorded that the Life Insurance Industry as a whole believed they are entitled to Cenvat Credit - extended period could not be invoked .....

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