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2019 (11) TMI 434

..... to an agreement by charging license fee to M/s Frigorifico Allana Ltd. through a contract - Extended period of limitation - validity of SCN - HELD THAT:- The said show cause notice came to be adjudicated by the Commissioner by way of passing two separate orders, one dated 10 January, 2014 and the other dated 19 September, 2014, which two orders are impugned before us by way of filing two separate .....

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..... f tax cannot be leveled against a Government Organization. Since the appellant is a local self-government, the allegation of intention to evade payment of tax is not sustainable against the appellant. Therefore extended period of limitation was not available to the Revenue in the present case - since the entire demand is beyond the normal period of limitation the same is not sustainable. Appeal al .....

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..... venue and perused the record. 2. We note that the appellant is a Municipal Corporation and after calling for tender, the appellant offered slaughter house belonging to them for operation and management to M/s Frigorifico Allana Ltd. by entering into an agreement by charging license fee to M/s Frigorifico Allana Ltd. through a contract dated 21.06.2002. It appeared to Revenue that the said transact .....

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..... rds the other appeal being Service Tax Appeal No.52986 of 2014, the issue involved is relating to handing over slaughter house belonging to the appellant to M/s Frigorifico Allana Ltd. after calling for tender for operation and management through contract dated 26 March, 2002 on payment of license fee. The said transaction appeared to be Renting of Immovable Property to Revenue, therefore, service .....

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