2015 (9) TMI 259

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....e Respondent : Shri A.B. Kulgod, Asst. Commissioner (AR) ORDER Per: M.V. Ravindran This appeal is directed against Order-in-Appeal AGS (169)31/09 dated 04.08.2009. 2. Heard both sides and perused the records. 3. The issue involved in this case is regarding service tax liability under the category of Erection and Commissioning Service for the amount realized by the appellant for Maha....

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....of limitation needs to be addressed in this case as the show-cause notice has been issued on 29.01.2008 and the demand of the tax liability for the months of June and September are within limitation. He would also submit that the appellant had not taken registration certificate due to the bonafide belief. 5. Learned DR on the other hand would draw our attention to the findings recorded by the a....

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....ecific category, in this case of erection and commissioning service. Appellant could have entertained a bonafide belief that as the activity undertaken by the appellant may not be covered under the category of erection and commissioning services and would be covered under the works contract which not in statue during the material period i.e 2006, they have not discharged the service tax under the ....