No Penalty Imposed: Bona Fide Belief in Non-Payable Service Tax u/s 78 of the Finance Act, 1994.

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....Penalty u/s 78 - Once it is categorically held by Commissioner (Appeals) that appellant was under a bonafide belief that service tax as demanded was not payable, then a view can not be entertained that the facts will justify imposition of penalty under Section 78 of the Finance Act, 1994 - AT....