TMI Blog2023 (2) TMI 235X X X X Extracts X X X X X X X X Extracts X X X X ..... r contends that there is no ground whatsoever in the impugned order, which could be read to indicate that it was not possible for the concerned authority to pass the order within the period as stipulated under Section 73(4B) of the Finance Act. Thus, the impugned order is barred by limitation. The petitioner also seeks to contest the demand on merits. Although, prima facie, the contention advan ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... x on 18.10.2014 for the six month period ending 30.09.2014. Subsequently, on 21.12.2015, it filed the return for the six month period ending on 31.03.2015. It is stated that the petitioner had regularly filed its service tax returns for the subsequent period as well. 3. Apparently, investigation was initiated in respect of the service tax liability of the petitioner and various notices were iss ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 20.12.2022, respondent no.1 passed an order raising a demand of ₹5,19,748/- including service tax and penalty. 5. The petitioner claims that the said demand was raised beyond the period of one year, as stipulated under Section 73(4B) of the Finance Act, and therefore, is barred by limitation. The petitioner had also raised a similar ground before the concerned officer. However, the same ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... orth Commissionerate. From the above, it is amply clear from the Demand cum SCN that assessee did not co-operate during investigations stage and in spite of repeated letters/summons issued to them, the assessee neither submit properly reply nor furnished relevant related documents to the Department, as such, the Show Cause notice was issued on 17.12.2020 under Section 73 and other provisions ..... X X X X Extracts X X X X X X X X Extracts X X X X
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