https://www.taxtmi.com/forum/issue?id=118173 The operative issue is whether the filing date for computing limitation for issuance of a service tax show cause notice is the original return date or the revised return date; while one view treats the original return as the relevant date, an Explanation to an implementing rule treats the revised return date as extending departmental time to issue an SCN, creating a tension between the Act and subsidiary rule which must be resolved in favor of the statute where conflict exists. en-us Wed, 28 Sep 2022 11:10:07 +0530 Thu, 23 Jan 2025 15:54:16 +0530 TaxTMI RSS Generator https://www.taxtmi.com/forum/issue?id=118173 The operative issue is whether the filing date for computing limitation for issuance of a service tax show cause notice is the original return date or the revised return date; while one view treats the original return as the relevant date, an Explanation to an implementing rule treats the revised return date as extending departmental time to issue an SCN, creating a tension between the Act and subsidiary rule which must be resolved in favor of the statute where conflict exists. Discussion-Forum Service Tax Wed, 28 Sep 2022 11:10:07 +0530 https://www.taxtmi.com/forum/issue?id=118173