Intermediary Export Services Dispute Dismissed Due to Limitation Period Expiry Under Service Tax Regulations

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....CESTAT adjudicated a service tax dispute involving an intermediary's export of services. The tribunal found the show cause notice (SCN) issued on 29.06.2020 was time-barred for the period from October 2014 to June 2017. Since the appellant regularly filed ST-3 returns declaring export service amounts and the department was aware of these declarations, the 30-month limitation period had expired. The tribunal held the entire demand was unsustainable and barred by limitation, thereby allowing the appeal without examining the substantive merits of the case. The key principle established was that when an assessee transparently declares service details in statutory returns, subsequent time-barred demands cannot be sustained.....