TMI Blog2019 (2) TMI 1857X X X X Extracts X X X X X X X X Extracts X X X X ..... cal) Shri Sita Ram, Consultant, for Appellant Shri Mohammad Altaf, Assistant Commissioner (AR), for Respondent ORDER Per: Archana Wadhwa 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 pe ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ibuted to them so as to invoke the longer period of limitation. He also submits that during the relevant period, the issue 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 ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... n. 4. Learned AR appearing for the Revenue reiterates the findings of the Lower Authorities and prays for rejecting the 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-fi ..... X X X X Extracts X X X X X X X X Extracts X X X X
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