Extended Limitation for Service Tax Not Applicable Due to Presumption Against Willful Suppression by Government Company per Sec 73(1.

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....Extended Period of Limitation - wilful suppression of facts with an intent to evade payment of service tax, or not - The appellant is a government company and, therefore, there is a rebuttable presumption regarding non-existence of any of the ingredients mentioned in the proviso to section 73(1) of the Finance Act. The show cause notice does not rebut the presumption - In such circumstances, the extended period of limitation could not have been invoked. - AT....