2024 (4) TMI 110

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....e of services rendered by them. 3. The brief facts of the case are that the Appellants have entered into an agreement with M/s SITD Ltd, Hyderabad to provide "Commercial Training or Coaching service" on behalf of M/s SITD Ltd, Bangalore under a franchise agreement during the period April 2005 to March 2007. Acting on the information received, the departmental officers visited the appellant's premises on 08.07.2009 and recorded a statement from the Proprietor - Mr. Md. M. Ansari on 07.07.2010. The appellants had stated that they are providing 'Commercial Training or Coaching service' on behalf of M/s SITD, Bangalore from 2005-06 onwards. The Appellants are providing some computer training courses like CTTC, CPAC, etc., during the period 2....

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....as to be filed with the department on 25.10.2005. So, the Show Cause Notice was issued by the Adjudicating Authority on 12.10.2010 which is well in 5 years as envisaged under Section 73(1) of the Finance Act, 1994. So, the objection of the assessee that the Show Cause Notice was time barred and not applicable to the period 04/2005 to 09/2005 is not sustainable in law. Since the appellants have not registered with the department under Section 69 of the Finance Act, 1994 the Show Cause Notice can be issued invoking the extended period of 5 years clause. Further the assessee had not furnished the full information vide their letter dated 15.07.2009 to the department again the same was changed in his statement dated 07.07.2010 given before the S....