Tribunal Decisions Support Non-Taxability: Extended Limitation Period Not Applicable for Bona Fide Belief in Non-Payment of Service Tax.

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....Extended period of limitation - Demand of Service Tax - It appears that non-payment of service tax could be on account of the belief that no service tax was payable in respect of the activities undertaken by the Appellants; that the very fact that various decisions of Tribunal referred to herein above have also held that no service tax is payable on activities such as those undertaken by the Appellants, itself shows that the Appellants’ belief was reasonable and bona fide. It is settled law that where demand has been worked out based on the records of maintained by the assessee and where non-payment of service tax is on account of bona fide belief that no service tax was payable, the larger period of limitation cannot apply. - AT....