Extended Limitation Period Invoked in Service Classification Dispute; No Fraud Alleged, No Demand Made by High Court.

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....Invocation of Extended period of Limitation - presence of two views as whether the service provided by the respondent is Management or Business Consultancy or not - It is not the case of the appellant (revenue) that there was either fraud perpetrated by the respondent or there has been any collusion or willful mis-statement of facts before the revenue. - No demand - HC....