The CESTAT held that the appellant's activity involving...

The CESTAT held that the appellant's activity involving fabrication of huts constitutes a works contract service, supported by evidence of VAT payments and material involvement integral to the work. The absence of formal contract agreements did not negate this classification, given the nature of government tendering and work orders. However, the Revenue failed to demonstrate any suppression, collusion, or misstatement by the appellant to justify invoking the extended period of limitation. Since invocation of extended limitation solely based on audit findings is impermissible, the extended period was disallowed. Consequently, despite merits favoring the appellant, the appeal was allowed on the ground of limitation, resulting in dismissal of the Revenue's claim beyond the prescribed period.