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    <title>2022 (4) TMI 202 - MADRAS HIGH COURT</title>
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    <description>Writ petitions challenging service tax show cause notices were not entertained at the notice stage because the petitioners had an adequate remedy in adjudication. The limitation plea under Section 73 of the Finance Act, 1994 was treated as only partly available, since the return due-date chart indicated that only part of the proposed demand could fall beyond five years. The absence of registration and failure to file returns also weakened the argument that the notices were barred for want of suppression. The claimed exemption under Notification No. 25/2012-ST, its withdrawal, and the later statutory and clarificatory measures were treated as requiring factual proof of compliance before the adjudicating authority.</description>
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      <link>https://www.taxtmi.com/caselaws?id=420536</link>
      <description>Writ petitions challenging service tax show cause notices were not entertained at the notice stage because the petitioners had an adequate remedy in adjudication. The limitation plea under Section 73 of the Finance Act, 1994 was treated as only partly available, since the return due-date chart indicated that only part of the proposed demand could fall beyond five years. The absence of registration and failure to file returns also weakened the argument that the notices were barred for want of suppression. The claimed exemption under Notification No. 25/2012-ST, its withdrawal, and the later statutory and clarificatory measures were treated as requiring factual proof of compliance before the adjudicating authority.</description>
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