Service Tax Notice Quashed After 20-Year Delay in Adjudication Under Section 65(95)(ZZZA) of Finance Act

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....HC quashed show cause notice due to unreasonable delay in adjudication spanning two decades. Department's internal CERA audit objection and conflicting views among Central Excise Officers led to prolonged inaction until January 2021. Court found petitioner had properly discharged service tax liability under works contract service per Section 65(95)(ZZZA) of Finance Act, 1994. Department's own Statement of Facts acknowledged disagreement with CERA audit findings. HC ordered refund of excess amounts deposited during investigation with 6% interest from payment date. Court affirmed petitioner's right to modify valuation method for service tax payment under Finance Act provisions.....