Alternate statutory remedy governs GST assessment challenge, with statutory appeal preserved and limitation objection barred for the permitted filing ...
Invocation of Extended period of limitation - respondent had a bonafide belief that it is entitled to Cenvat Credit in respect of all inputs hence there is no occasion of making of declaration in ST-3 Returns would arise - even Commissioner of Service Tax has himself recorded that the Life Insurance Industry as a whole believed they are entitled to Cenvat Credit - extended period could not be invoked
Invocation of Extended period of limitation - respondent had a bonafide belief that it is entitled to Cenvat Credit in respect of all inputs hence there is no occasion of making of declaration in ST-3 Returns would arise - even Commissioner of Service Tax has himself recorded that the Life Insurance Industry as a whole believed they are entitled to Cenvat Credit - extended period could not be invoked
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