2026 (5) TMI 61

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....tax in terms of the provisions of the Finance Act, 1994. Petitioner has also challenged the order in appeal at Annexure-D whereby the appeal came to be rejected on the ground that the appeal was filed beyond the time limit prescribed for filing the appeal and the Authority could not entertain the appeal after the prescribed period. 2. Learned counsel for the petitioner would submit that the order is passed on the basis of inputs received from the Central Board of Direct Taxes and in such cases, this Court in W.P.No.11154/2023 had set aside the order and remitted the matter back for fresh consideration. 3. Petitioner has raised various contentions including that the proceedings were initiated after prescribed period and also regarding ....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....ered under negative list ? 3) Whether services are covered under the exemption list under the Notification No.25/2012-ST dated 28.06.2012 or under any other applicable Notifications? 4) Whether the person is liable to remit service tax in terms of Rule 2 (1) (d) read with applicable notification? 5) Whether claims are barred by limitation in terms of the law laid down by the Apex Court? 11. It is also clarified that disposal of present petitions must not be construed as having adjudicated any of the contentions including jurisdiction. All contentions of both sides on merits are kept open. 12. Needless to state, upon conclusion of proceedings, if any of the petitioners are still aggrieved, legal r....