https://www.taxtmi.com/caselaws?id=388912 Strict interpretation of exemption notifications required Notification No. 31/2012-ST to be read according to its plain terms: before the amendment effective from 01.04.2015, transport of export goods by GTA was covered only up to a port or airport, so exports through a land customs station did not qualify. The amendment inserting land customs station was therefore treated as a new coverage, not a clarification. On limitation, the longer period was held unavailable because the department knew the relevant export route and the procedural requirements had been followed, with no mala fide conduct shown. Penalty was also not sustainable on the same facts. en-us Mon, 01 Jul 2019 00:00:00 +0530 Tue, 27 Oct 2020 12:28:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388912 Strict interpretation of exemption notifications required Notification No. 31/2012-ST to be read according to its plain terms: before the amendment effective from 01.04.2015, transport of export goods by GTA was covered only up to a port or airport, so exports through a land customs station did not qualify. The amendment inserting land customs station was therefore treated as a new coverage, not a clarification. On limitation, the longer period was held unavailable because the department knew the relevant export route and the procedural requirements had been followed, with no mala fide conduct shown. Penalty was also not sustainable on the same facts. Case-Laws Service Tax Mon, 01 Jul 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388912