Extended period of limitation - manpower recruitment or supply...

Extended period of limitation - manpower recruitment or supply agency service - separate employment contract with foreign expatriates - even if it were to be assumed that the appellant had received manpower supply services, the fact remains that the whole of the activities were within the knowledge of the Revenue / officials of the Department and hence, there is no scope whatsoever to allege suppression of any facts - the issue, therefore, involved classification and interpretation of taxing statute, for which reason also suppression of facts could not be alleged. - Demand confirmed for the normal period only - AT