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    <title>2010 (4) TMI 503 - CESTAT, MUMBAI</title>
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    <description>A show cause notice under section 73 of the Finance Act, 1994 for alleged non-filing of returns in respect of Goods Transport Operator services was not maintainable for the relevant pre-2003 period. The legal point was that, during that period, the obligation to file returns for recipients of such service had not yet been brought within section 70, and the later section 71A created that return-filing requirement only subsequently. On that basis, section 73 could not be used to sustain a notice for a default that was not then covered by the return-filing framework.</description>
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