2018 (10) TMI 31

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... Prabhat Kumar, Advocate, Mr. Arjun Malik, Advocate Present for the Respondent: Mr. Sanjay Jain, D.R. ORDER PER: RACHNA GUPTA The appeal is directed against the order No. 912 dated 5^th April 2013. The relevant facts for the adjudication are as follows:- 1.1 That the appellants were engaged in the business of marketing, sourcing, making available various kind of loans on behalf of v....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ggrieved, the present appeal. 2. We have heard Mr. Prabhat Kumar, ld. Advocate for the appellant and Mr. Sanjay Jain, ld. DR for the Revenue. 3. It is submitted on behalf of the appellant that they have entered into agreements with the various banks in accordance thereof the appellant were appointed as direct sale agents and franchise service provider to these Banks. There was confusion abou....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....e there was an apparent acknowledged confusion about the impugned activity, non-discharge of the liability thereof cannot be alleged as an act of suppression of fact with an intent to evade tax. Resultantly, the Department was not entitled to invoke the extended period of limitation. The demand in question therefore is hit being barred by time. Irrespective of the liability of the appellant for re....