Extended Service Tax Limitation: Initial Burden on Department to Prove Proviso Conditions Before Shifting to Appellant.

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....Extended period of limitation - The initial burden is on the department to prove that the situations visualised by the proviso existed. But once the department is able to bring on record material to show that the appellant was guilty of any of those situations which are visualised by the section, the burden shifts and then applicability of the proviso has to be construed liberally - HC....