2019 (2) TMI 313

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.... Shri Sita Ram, Consultant for the Appellant (s) Shri Gyanendra Kumar Tripathi (A.C.) (A.R.) for the Revenue ORDER Per Mrs. Archana Wadhwa : As per facts on record the appellants entered into a contract with M/s.Obra Thermal Power Station for providing repair and maintenance services. As per the contract entered into between the two, all the terms of contract indicated the value of ....

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....f the appellant fairly agrees that the value of the goods were not separately shown by them either in the contract or in the Bills so raised, but assails the impugned order on the point of limitation by submitting that the period involved in all the appeals is from 2006/07 to 2010/11 and the show cause notice stands issued on 04.10.2011. He submits that that the services were being provided to a P....

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....e contracts entered by them with the said Public Sector Undertaking. In such a scenario we are of the view that the appellant was entertaining a bona fide belief and there was no mala fide on their part so as to justifiably invoke the longer period of limitation. Accordingly we hold that extended period is not available to the Revenue. However, as a part of demand falls within the limitation perio....