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NOTE:
CESTAT held that the extended period of limitation was wrongly invoked in the first show cause notice. The service tax demand on amounts received from foreign counterparts under reverse charge mechanism is upheld within the normal limitation period. The appellant's incorrect understanding of tax law was deemed a reasonable cause. All penalties were set aside under section 80. The appeal was partially allowed, with the matter remanded to the Commissioner for calculating and appropriating tax and interest payments already made.