Extended period of limitation not available in revenue neutral situation

Rolex Rings Pvt. Ltd. Vs C.C.E. & S.T. (CESTAT Ahmedabad) CESTAT find that in the present matter Ld. Counsel strongly defended the liability on the ground of limitation. As regards the question of extended period of limitation under proviso to Section 73(1) of the Finance Act, 1994, the same would not be available to the Department on the ground of revenue neutrality. We also find that, as no intention to contravene the provisions of Finance Act, 1994 and of the rules made thereunder can be attributed to the appellant for the reason that even if they are required to pay Service Tax on the ...