Service Tax Demand on PDS Transporters Unjustified; Penalties Under Finance Act Sections 77 & 78 Overturned.

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....Extended period of limitation - GTA - The appellants had mostly undertaken carrying food and other items as part of PDS. So it cannot be said that appellant has wilfully suppressed any facts and so demand in respect of GTA invoking extended period cannot be sustained. As such, penalties imposed under Sections 77 & 78 of the Finance Act, 1994 are not warranted. - AT....