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Court Dismisses Service Tax Demand Due to Misapplication of Extended Limitation and Non-Compliance with Section 73(1) Proviso.

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....Levy of service tax - reverse charge mechanism - The impugned order does not discuss the ingredients necessary for invocation of extended period of limitation nor does it invoke the proviso to Section 73(1) in the operative part of the order. It is for this reason that we have to set aside the impugned order for the extended period of limitation. The demand within the normal limitation is not covered by the charging sections invoked - entire demand needs to be set aside and we do so. - AT....