The answer is No.

 As decided by the Tribunal in Jindal Vegetable Products Ltd. Versus CCE [2013 (3) TMI 56 - CESTAT, NEW DELHI]  that:

"....The appellant cannot be accused of suppressing the relevant information from the department as during the period of dispute there was doubt about the levy of service on the renting of immovable property till the dispute was put to an end by retrospective amendment made by Finance Act, 2010. Hon'ble Apex Court in the case of Continental Foundation Jt. Venture (2007 (216) ELT 177), has held that when during the period of dispute there was doubt about interpretation of some provisions of law on account of conflicting judgments, which were later on resolved by a Larger Bench, the extended period under proviso to Section 11A (1) cannot be invoked."

Therefore, the amendment to the section 80 vide Finance Act, 2012 to grant immunity form penalty has limited application where demand has been raised within normal period of limitation as long as issue pertains to the period prior to retrospective amendment came into force i.e. 28-5-2012.

 

Jindal Vegetable Products Ltd. Versus CCE - 2013 (3) TMI 56 - CESTAT, New Delhi

Extended period of limitation cannot be invoked for pre-amendment service tax on renting of immovable property where genuine doubt existed. Service tax demands for renting of immovable property predating the retrospective amendment cannot rely on the extended period of limitation where genuine doubt existed about levy; conflicting judicial views negate invocation of the extended period. The Finance Act, 2012 amendment granting penalty immunity applies narrowly to demands raised within the normal limitation period and does not broadly validate extended-period demands for pre-amendment periods.