CESTAT held that the appellant's claim of exemption under...

CESTAT held that the appellant's claim of exemption under Notification No. 25/2012-ST fails because the recipient was a state government company and not a statutory authority created by statute; therefore the notification is inapplicable. The Tribunal affirmed invocation of the extended period of limitation, finding no complex questions and noting prior judicial determination of the recipient's status and contemporaneous evidence that service tax was paid only from October 2013, establishing intent to short-pay/evade tax. Penalty under section 78 was upheld; challenges to penalties under section 77(1)(a) and late fee under section 77(2) were not pursued. The appeal was dismissed.