2020 (7) TMI 700

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....L G. SHAKKARWAR The above stated three appeals are taken together for decision since they arise out of common impugned Order-in-Original dated 31.12.2018. 2. The brief facts of the case are that the main appellant were providing various services & were registered with Service Tax Department since 22.09.2008. The main appellant opted for VCES Scheme and declared their unpaid service tax liability of Rs. 63,88,125/- up to 31.12.2012, paid the same and received immunity from any proceedings for the period upto 31.12.2012. The appellants were issued with show cause notice dated 05.06.2017 for the period from 01.01.2013 to 30.09.2015 raising demand of Service Tax under proviso to Sub-section (1) of Section 73 of Finance Act, 1994 by inv....

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....ibid on the two appellants. Hence the above stated three appeals. 3. We have heard Shri Abhinav Kalra learned Chartered Accountant on behalf of all the three appellants. He has made following submissions:- a) Section 73 (3) of Finance Act, 1994 provided that if there are no ingredients for invocation of extended period of limitation for raising a demand in respect of Service Tax then in respect of Service Tax paid before issue of show cause notice there is no provision for issue of show cause notice. b) The learned Original Authority has accepted that the main appellant had voluntarily deposited Rs. 4,79,89,170/- before issue of show cause notice. c) The learned Original Authority has accepted that the details ....