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    <title>2011 (2) TMI 671 - CESTAT, MUMBAI</title>
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    <description>Recipients of goods transport operator service were liable to file returns under Section 71A, but before 10-09-2004 Section 73 of the Finance Act, 1994 did not refer to that obligation and remained confined to assessees covered by Section 70. The substitution of Section 73 was held to operate prospectively, and the provision could not be expanded by reading in words based on legislative intent. Applying the earlier L.H. Sugar Factories ruling, show cause notices issued under Section 73 before 10-09-2004 against GTO service recipients were held not maintainable, so the demand could not be sustained.</description>
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      <link>https://www.taxtmi.com/caselaws?id=207348</link>
      <description>Recipients of goods transport operator service were liable to file returns under Section 71A, but before 10-09-2004 Section 73 of the Finance Act, 1994 did not refer to that obligation and remained confined to assessees covered by Section 70. The substitution of Section 73 was held to operate prospectively, and the provision could not be expanded by reading in words based on legislative intent. Applying the earlier L.H. Sugar Factories ruling, show cause notices issued under Section 73 before 10-09-2004 against GTO service recipients were held not maintainable, so the demand could not be sustained.</description>
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