Extended Limitation Period Not Applicable for Overseas Commission; No Malafides in Non-Payment of Service Tax Under RCM.

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....Extended period of limitation - commission to their overseas agent - whatever service tax would have been paid by the appellant under reverse charge mechanism, the same is entitled as the Cenvat credit - therefore, malafides on the part of the appellant are missing for non-payment of service tax under RCM - the extended period of limitation is not invokable....