Inconsistent Service Classification by Department Challenges Extended Limitation Period for Tax Show Cause Notices.

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....Extended period of limitation - SCN issued for two times for different period classifying the services differently - The department had earlier raised the demand as Intellectual Property Service which could not sustain and in the impugned period has tried classifying the same under Consulting Engineer Service. This seems to be inconsistent view of the department itself and cannot be attributed as intent to evade on the part of the assessee. - AT....