Service Tax Demand Overturned: Improper Use of Extended Limitation Period Due to Appellant's Transparency with Department.

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....Demand of service tax - Extended period of limitation - In place of invoking extended period in cases of suppression of fact with an intent to evade payment of duty or tax, it is found that the department chose to invoke extended period in a case where the appellant has proactively informed the department about their activities and sought clarification. The Revenue had no case to invoke the extended period to issue show-cause notice - the impugned order does not survive on limitation either. - AT....