Extended Limitation Under Finance Act Section 78(1) Challenged; No Fact Suppression Found, Limitation Not Invoked.

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....Invocation of Extended period of limitation u/s 78(1) of FA - Department was at all times during the period for which the demand has been raised were aware of the declaration made by the respondent that they will not be liable to pay the service tax on 41% levy collected from the contractee and paid over to the Grocerty Market and Shop Board - no suppression of facts to invoke the extended period of limitation....