TMI Blog2020 (8) TMI 29X X X X Extracts X X X X X X X X Extracts X X X X ..... Sub Rule (1) of Rule 7 specifies the form that has to be used while filing the half yearly returns, Sub Rule(3) clarifies the manner in which the half yearly returns have to be filed by an assessee after 01.10.2011. When so read harmoniously, it would follow that the half yearly return that has to be submitted in the particular form mentioned in Sub Rule (1) had necessarily to be submitted electro ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ildings, has approached this Court seeking a direction to the respondents to accept Ext.P1 return preferred by the petitioner in manual form. The averments in the writ petition would indicate that the petitioner intends to avail the benefit of the 'Sabka Vishwas (Legacy Dispute Resolution) Scheme, 2019' where a distinction is made between persons, who have filed returns showing the extent ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and Sri.Sreelal N. Warrier, the learned Standing Counsel for the respondent. 3. Sri.A.Kumar would refer to Section 70 of the Finance Act, 1994 as amended, as also to Rule 7 of the Service Tax Rules, 1994, to point out that prior to 01.10.2011, when Sub Rule (3) was introduced to Rule 7 of the Service Tax Rules, the half yearly return that had to be filed by an assessee could be filed in manual ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... force in the contention of the learned counsel for the respondents that Sub Rule (3) of Rule 7 only qualifies Sub Rule (1) of Rule 7. In my view, while Sub Rule (1) of Rule 7 specifies the form that has to be used while filing the half yearly returns, Sub Rule(3) clarifies the manner in which the half yearly returns have to be filed by an assessee after 01.10.2011. When so read harmoniously, it w ..... X X X X Extracts X X X X X X X X Extracts X X X X
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