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CESTAT allowed the appeal, finding the service tax demand for the period 01.10.2014 to 30.06.2017 wholly barred by limitation. The tribunal held that the jurisdictional officers failed to scrutinize the appellant's returns, which consistently declared export of services. The extended limitation period was improperly invoked, as the department had prior knowledge of the appellant's service tax declarations. Given the limitation bar, the tribunal refrained from examining the substantive merits of the case, particularly noting the subsequent GST regime's implementation and the department's own prior favorable order for subsequent periods.
CESTAT allowed the appeal, finding the service tax demand for the period 01.10.2014 to 30.06.2017 wholly barred by limitation. The tribunal held that the jurisdictional officers failed to scrutinize the appellant's returns, which consistently declared export of services. The extended limitation period was improperly invoked, as the department had prior knowledge of the appellant's service tax declarations. Given the limitation bar, the tribunal refrained from examining the substantive merits of the case, particularly noting the subsequent GST regime's implementation and the department's own prior favorable order for subsequent periods.
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