Bona fide belief/Retrospective amendment in law doesn’t warrant invocation of extended period of limitation

HIGH COURT OF DELHI Infinity Infotech Parks Ltd. Versus Union of India W.P. NO. 21549 (W) OF 2012 SEPTEMBER 28, 2012 JUDGMENT 1. This writ petition has been filed challenging show cause notice-cum-demand being C. No. V(3) 222/SCN/Adjn/Infinity/ST/11/457 dated 18th April, 2012 wherein it has been alleged that service tax amounting to Rs. 9,53,69,284/- including cess was due and payable by the petitioner-company for the service of renting of immovable property during the period 2007-2008, 2008-2009, 2009-2010 and 2010-2011. Under Section 65(105)(zzzz) of the Finance Act, 1994 an...