Extended limitation upheld under Section 129(2)(c) for suppressed CENVAT credit in SVLDRS declaration

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....The CESTAT upheld the invocation of extended limitation under Section 129(2)(c) of the Finance Act, 2019, rejecting the appellant's contention that the SCN was time-barred. The appellant failed to disclose CENVAT credit utilization while declaring liability under SVLDRS, rendering their declaration substantially false. Their omission constituted suppression of facts with intent to evade service tax, justifying extended limitation and demand recovery. The tribunal found that the appellant did not dispute the tax liability but improperly sought to net it against undisclosed CENVAT credit. The penalty under Section 78 was sustained as justified. Consequently, the appeal was dismissed for lack of merit.....