https://www.taxtmi.com/caselaws?id=444277 The Tribunal ruled in favor of the appellant, setting aside the impugned order and granting consequential benefits. It held that the show cause notice was a change of opinion rather than based on new facts, concluding that the extended period of limitation cannot be invoked solely on a change of opinion. The Tribunal noted the appellant's regular filing of returns and previous audit without objections, indicating the Revenue's prior knowledge of the appellant's affairs. The appellant's challenge on grounds of limitation and change of opinion was upheld, resulting in the appeal being allowed. en-us Thu, 05 Oct 2023 00:00:00 +0530 Thu, 12 Oct 2023 10:30:10 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=444277 The Tribunal ruled in favor of the appellant, setting aside the impugned order and granting consequential benefits. It held that the show cause notice was a change of opinion rather than based on new facts, concluding that the extended period of limitation cannot be invoked solely on a change of opinion. The Tribunal noted the appellant's regular filing of returns and previous audit without objections, indicating the Revenue's prior knowledge of the appellant's affairs. The appellant's challenge on grounds of limitation and change of opinion was upheld, resulting in the appeal being allowed. Case-Laws Service Tax Thu, 05 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=444277