Extended period of demand not invokable if no mala-fide intention or suppression of fact by assessee

Patel Labour Contractor P Ltd Vs C.S.T. Service Tax (CESTAT Ahmedabad) It is settled that if on any issue there is a legal dispute which involved interpretation of law the mala-fide intention or suppression of fact with intent to evade payment of service tax cannot be attributed to the assessee. On this ground also the extended period of demand was not invokable. As per the facts in the present case the period of dispute i.e. 2005-06 to 2009-10 and show cause notice was issued on 19.05.2011. It is also observed that the appellant has filed their ST-3 return covering the period October 2009 to ...