2024 (1) TMI 1120

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....cy Service" and "Commercial Training or Coaching Service"; however, during the impugned period i.e. 2014-15 to 2016-17, they provided only Manpower Recruitment/ Supply Agency Service; A.G, Audit conducted an audit of the records of the appellants and noticed that the appellants have not filed ST-3 Returns for the period April 2014; Department issued a show-cause notice dated 13.11.2019 to the appellant, inter alia, relying on the data supplied by the Income Tax Department; it was alleged that service tax of Rs.6,72,669/- should be recovered from them along with interest; the appellants contented that they have enough credit to pay the demanded service tax and have discharged the same whereas Department contended that the appellants have tak....

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....IOL-778-CESTATKOLKATTA. 3. Learned Counsel further submits that the demands pertain to the period 2014 to 2017 and the show-cause notice was issued on 31.11.2019; there is no suppression of material facts on the part of the appellants; therefore, the demand is time barred. He relies on the following cases: • Chemphar Drugs & Liniments - 1989 (40) ELT 276 (SC). • Padmini Products - 1989 (43) ELT 195 (SC). • Pushpam Pharmaceuticals Company - 1995 (78) ELT 401 (SC). • Uniworth Textiles Ltd. - 2013-TIOL-13-SC-CUS. • Continental Foundation Jt. Venture - TIOL-1312- CESTAT-MUM. 4. Shri Ravinder Jangu, learned Authorized Representative for the Department, reiterates the findings....