https://www.taxtmi.com/caselaws?id=464114 CESTAT allowed the appeal, holding the extended limitation period could not be invoked because the SCN failed to allege violations under Sec. 73(1) and was issued after four years, relying on SC authority. The Tribunal found the contracts were for software development - not manpower supply - so services are software services; even if reverse charge applied, tax paid would have been available as CENVAT credit and refundable under Rule 5. The demand and interest in the impugned order, and the penalties, were set aside. en-us Thu, 20 Jun 2024 00:00:00 +0530 Wed, 29 Oct 2025 15:11:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=464114 CESTAT allowed the appeal, holding the extended limitation period could not be invoked because the SCN failed to allege violations under Sec. 73(1) and was issued after four years, relying on SC authority. The Tribunal found the contracts were for software development - not manpower supply - so services are software services; even if reverse charge applied, tax paid would have been available as CENVAT credit and refundable under Rule 5. The demand and interest in the impugned order, and the penalties, were set aside. Case-Laws Service Tax Thu, 20 Jun 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=464114