https://www.taxtmi.com/caselaws?id=451143 CESTAT Ahmedabad allowed the appeal, ruling that the appellant did not arbitrarily bifurcate services under two separate categories (Manpower Recruitment and GTA service) as they had entered into two legally valid separate agreements with the service recipient on different dates. The tribunal held that individual contracts must be considered for service tax levy purposes. Regarding extended limitation period, CESTAT found no suppression of facts, fraud, or misstatement as both parties regularly filed ST-3 returns with complete service details. The department's invocation of extended period under Section 73(1) of Finance Act, 1994 was deemed improper, and the impugned order lacked merit. en-us Wed, 20 Mar 2024 00:00:00 +0530 Thu, 21 Mar 2024 06:58:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=451143 CESTAT Ahmedabad allowed the appeal, ruling that the appellant did not arbitrarily bifurcate services under two separate categories (Manpower Recruitment and GTA service) as they had entered into two legally valid separate agreements with the service recipient on different dates. The tribunal held that individual contracts must be considered for service tax levy purposes. Regarding extended limitation period, CESTAT found no suppression of facts, fraud, or misstatement as both parties regularly filed ST-3 returns with complete service details. The department's invocation of extended period under Section 73(1) of Finance Act, 1994 was deemed improper, and the impugned order lacked merit. Case-Laws Service Tax Wed, 20 Mar 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=451143