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    <title>2012 (2) TMI 271 - CESTAT, NEW DELHI</title>
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    <description>Service tax proceedings could not be revived through revalidation legislation where, at the relevant time, the service recipient had no statutory obligation to file a return or discharge tax liability. On that factual and legal basis, Section 73 of the Finance Act, 1994 could not be invoked against the appellant, and the notice was also held to be barred by limitation. The revalidation plea was therefore insufficient to sustain proceedings that had already attained finality in the earlier round, and the proceedings were found not invokable and time-barred.</description>
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    <pubDate>Wed, 11 Jan 2012 00:00:00 +0530</pubDate>
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      <title>2012 (2) TMI 271 - CESTAT, NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=210783</link>
      <description>Service tax proceedings could not be revived through revalidation legislation where, at the relevant time, the service recipient had no statutory obligation to file a return or discharge tax liability. On that factual and legal basis, Section 73 of the Finance Act, 1994 could not be invoked against the appellant, and the notice was also held to be barred by limitation. The revalidation plea was therefore insufficient to sustain proceedings that had already attained finality in the earlier round, and the proceedings were found not invokable and time-barred.</description>
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      <pubDate>Wed, 11 Jan 2012 00:00:00 +0530</pubDate>
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