2023 (9) TMI 571

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....MBER ( TECHNICAL ) Shri Mehul Jivani , Chartered Accountant , for the Appellant Shri Prabhakar Sharma , Superintendent , Authorised Representative for the Respondent ORDER PER : ANIL G. SHAKKARWAR Brief facts of the case are that the appellant provides various services to their clients and is registered with Service Tax. Appellant has also taken centralized registration in respect o....

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....t, 1994, raised a demand of service tax of Rs.60,17,195/- through the said show cause notice. The said show cause notice also had proposals for imposition of penalty and recovery of interest. Appellant contested the show cause notice and stated in their reply dated 21.10.2015 that the appellant was required to pay service tax in respect of 16 branches and head office for the month of September 201....

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....e has submitted that Rule 6(4A) of Service Tax Rules, 1994 provides for adjustment of excess paid service tax during the succeeding month. He has submitted that the rule does not require adjustment to be made during the immediate succeeding month but in the succeeding month as can be interpreted by the provisions of the said rule. He has submitted that Revenue has invoked the provisions of Rule 6(....

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.... within the knowledge of Revenue through ST-3 return for that month when the adjustment was done by the appellant and, therefore, there was no suppression on the part of the appellant to enable Revenue to invoke extended period of limitation. 3. Heard the learned AR for Revenue. He has supported the impugned order. 4. We have carefully gone through the record of the case and submissions made....