Extended period cannot be invoked in case of revenue neutral situation

Star Alloys & Chemicals Pvt. Ltd. Vs. CCE & ST (CESTAT Delhi) CESTAT has held that in the case of GTA service, CENVAT credit is available, therefore extended period cannot be invoked. Learned Advocate submits that whatever service tax was payable by them on the said GTA services, the same was available as a credit to them. As such, the entire situation was revenue neutral, in which case the longer period of limitation would not apply. In as much as the demand has been raised by invoking the extended period, the same is barred by limitation. I find that admittedly, the service tax paid ...