TMI Blog2019 (2) TMI 1857X X X X Extracts X X X X X X X X Extracts X X X X ..... ution, which is wholly owned by Government of India. As such, in terms of the Hon ble Rajasthan High Court s decision COMMISSIONER CENTRAL EXCISE, JAIPUR-I VERSUS RAJASTHAN RENEWABLE ENERGY CORPORATION LTD [ 2018 (8) TMI 1690 - RAJASTHAN HIGH COURT] , no mala-fide can be attributed to them so as to justifiably invoke the longer period of limitation - As such, the demand beyond the normal period is ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a As per the facts on record the appellant, which is a Central Government Educational Institution, was registered with the Service Tax Department under the Category of Scientific Technical Consultancy Technical Inspection Certification. During the period 2007-08 to 2011-12, they also provided certain services falling under the category of Service of Renting of Immovable Property. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... of Taxability of Renting of Immovable Property was under litigation before various High Courts and the issue was not free from doubt. They were also entertaining a bona-fide belief that inasmuch as they are an educational institution, there would not be any Tax liability upon them. For all the above reasons, he prays for setting aside the demand falling outside the normal period of limitation and ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... appeal. 5. After appreciating the submissions made by both the sides, we find that the appellant is admittedly an educational institution, which is wholly owned by Government of India. As such, in terms of the Hon ble Rajasthan High Court s decision referred (supra), no mala-fide can be attributed to them so as to justifiably invoke the longer period of limitation. As such, we hold that the dem ..... X X X X Extracts X X X X X X X X Extracts X X X X
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