https://www.taxtmi.com/caselaws?id=177647 A service recipient liable to file returns under Section 71A was treated as outside the scope of Section 73, as then framed, for purposes of the show cause notice. The Court applied earlier rulings that the relevant date for limitation had to be linked to the return obligation under Section 71A, not Section 71. It noted that the retrospective validation of the levy did not change the statutory basis on which the notice had to be tested. On that footing, the notice was held unsustainable on the Tribunal's approach and the appeal succeeded for the assessee. en-us Wed, 11 Feb 2015 00:00:00 +0530 Thu, 14 Jan 2016 12:32:44 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=177647 A service recipient liable to file returns under Section 71A was treated as outside the scope of Section 73, as then framed, for purposes of the show cause notice. The Court applied earlier rulings that the relevant date for limitation had to be linked to the return obligation under Section 71A, not Section 71. It noted that the retrospective validation of the levy did not change the statutory basis on which the notice had to be tested. On that footing, the notice was held unsustainable on the Tribunal's approach and the appeal succeeded for the assessee. Case-Laws Service Tax Wed, 11 Feb 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=177647