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Extended period limitation - ST liability on payment to overseas Sales Commission Agent under RCM - being CENVAT was available,it is Revenue neutral situation - it cannot be said that there was malafide intention on the part of the appellant in non-payment of service tax - extended period was clearly not invokable
Extended period limitation - ST liability on payment to overseas Sales Commission Agent under RCM - being CENVAT was available,it is Revenue neutral situation - it cannot be said that there was malafide intention on the part of the appellant in non-payment of service tax - extended period was clearly not invokable
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