2026 (7) TMI 996

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.... service tax invoking extended period of limitation. The Commissioner (Appeals) in the impugned order confirmed the Service tax demand along with interest under the category of 'Intermediary Services' for the period from October 2015 to June 2017 and imposed various penalties under Section 77 and 78 of the Finance Act, 1994. Aggrieved by this order, the appellant is in appeal before the Bench. 2. The Learned Chartered Accountant, at the time of hearing, submitted that he would like to challenge the impugned order only on the ground of limitation and accordingly, submitted that as per Section 73(6)(i)(c) of the Finance Act, 1994, the relevant date for issuing show-cause notice in the present case where the appellant is not registered was ....

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....ing that the appellant had intentionally not registered with the department to evade payment of service tax and on bona fide belief the appellant had not discharged service tax. 3. The learned Authorised Representative (AR) reiterated the findings of the Commissioner (Appeals) in the impugned order. 4. Heard both sides. Since the appellant is not challenging the issue on merits, the only question to be looked into is whether Revenue was justified in invoking the extended period of limitation. Based on the investigations and on the records of the appellant, the notices have been issued to determine the liability under 'Intermediary Services'. The original authority observes that non-disclosure of details of services rendered in itself ....