2016 (11) TMI 871

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....earing on behalf of the applicants submit that there are errors apparent on the face of the records as follows:- (a) On limitation, it was extensively argued that extended period cannot be invoked, The Bench has not recorded any findings and has also not considered the submissions that an investigation in these cases started since 2008 and show-cause notice was issued almost after four years. It is his submission that the applicants had bonafide belief that they are not liable to pay service tax, He submits that the order of the Bench has not recorded any independent views on these points and more specifically, in respect of the ratio of the Tribunal in the care of Charanjeet Singh Khanuja and Ors. - 2015-TIOL -1205-CESTAT-DEL which was ci....

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....ion Of can seen the ratio of the Tribunal in the case of Shri Surendra Singh Rathore and Smt Chanda Bohra (supra) in paragraph No. 7 directly applies in the case in hand wherein identical. set of facts was there and invocation of extended period was also upheld. We do not find any difference in the facts of that case and in the facts in these cases. As regards the case law relied upon by the learned Counsel in the case of Charanjeet Singh Khanuja and Ors. (supra) we find that in that case, the facts were very much different inasmuch as that the lower authorities were themselves confused and held contradictory views. This is apparent from the findings of the Bench in paragraph No. 16 of that case which is as under:- "We also take notice of ....