2006 (12) TMI 12

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.... has been posted today for deciding upon the appellant's plea of limitation. After hearing both the sides, we find that the show cause notice was issued on 23-6-03 for the period 16-7-1997 to 31-8-1999 on the alleged ground that the appellants, who are basically Commission Agents, are liable to pay Service Tax as Clearing and Forwarding Agents. The notice proposed invocation of longer period of li....

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....that the appellants were under bona fide belief that they are not covered by the definition of said services. It was under that belief that the appellant did not apply for Service Tax Registration and followed the subsequent procedures. The Revenue has not placed any positive evidence record to show that the appellant suppressed the information with an intention to evade payment of duty. As such, ....