https://www.taxtmi.com/caselaws?id=794443 For the period before 01.07.2012, service tax payable on imported services under reverse charge could be discharged through CENVAT credit because the recipient was treated as the person liable to pay tax and, by legal fiction, as the provider of taxable service. The later Explanation to Rule 3(4), which barred such utilisation, was held to be a substantive restriction operating prospectively from 01.07.2012 and not retrospectively. On limitation, the Tribunal found no basis for the extended period once credit utilisation was held permissible, and held the notice time-barred. The demand and penalties were therefore unsustainable. en-us Fri, 03 Jul 2026 00:00:00 +0530 Mon, 06 Jul 2026 08:26:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=794443 For the period before 01.07.2012, service tax payable on imported services under reverse charge could be discharged through CENVAT credit because the recipient was treated as the person liable to pay tax and, by legal fiction, as the provider of taxable service. The later Explanation to Rule 3(4), which barred such utilisation, was held to be a substantive restriction operating prospectively from 01.07.2012 and not retrospectively. On limitation, the Tribunal found no basis for the extended period once credit utilisation was held permissible, and held the notice time-barred. The demand and penalties were therefore unsustainable. Case-Laws Service Tax Fri, 03 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=794443