The appellant had a bona fide belief that services provided by foreign service providers outside India were not taxable. CESTAT held that since there was revenue neutrality due to availability of CENVAT credit, the extended period for demand could not be invoked as there was no intention to evade service tax. Relying on previous decisions, CESTAT concluded that the demand raised for the extended period was unsustainable. The impugned order was set aside and the appeal allowed.

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