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Extended Limitation u/s 73(1) Not Applicable Due to Unmet Conditions; Bona Fide Belief on Tax Liability.
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....Extended period of limitation - The ingredients mentioned in terms of proviso to Section 73(1) has not been fulfilled by the Department and moreover in the present case, the appellant has a bona fide belief that they are not liable to pay service tax on the differential freight amount collected - the issue involved relates to interpretation of provisions of a statute and in such a situation, extended period cannot be invoked. - AT....