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Show cause notice invalid: Tax paid with interest before notice; no willful suppression u/s 73(3).

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....Extended period of limitation - Section 73(3) - even when an assessee has suppressed facts, the extended period of limitation can be invoked only when “suppression’ is wilful with an intent to evade payment of service tax. - The show cause notice could not have been issued as the Appellant had paid the service tax with interest before the service of the show cause notice and had also informed the Department of this fact.....

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Show cause notice invalid: Tax paid with interest before notice; no willful suppression u/s 73(3).