Mandatory requirements contemplated in Act for invoking proviso...

Mandatory requirements contemplated in Act for invoking proviso to Section 73(1) stated in show cause notice regarding petitioner's liability for service tax and penalties. After show cause notice under proviso, inquiry conducted, and opportunity given for reply, grounds urged by petitioner to be challenged through appeal under Act instead of challenging jurisdiction for issuance. Writ jurisdiction under Article 226 not entertainable when efficacious statutory appeal remedy available u/s 85. No cogent reasons shown for revenue not providing sufficient cause to invoke extended limitation period. Petition dismissed.

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