Appellant Challenges Differential Tax Demand on Reverse Charge Mechanism; Claims Revenue-Neutral Situation Invalidates Extended Demand Period.

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....Demand of differential tax - There are force in the contention of the appellant that part of the service tax being demanded by the Department on RCM basis cannot be sustained since Service tax was already collected by Service Providers as seen from invoices and Reconciliation Certificate. - invoking extended period cannot be sustained for part of tax demand raised on RCM basis by virtue of it being a revenue neutral situation since the appellant is eligible for credit if it had done tax payment. - AT....