If dept change its view on taxability then Extended period of limitation not invocable

CESTAT, AHMEDABAD BENCH Gujarat State Seeds Certification Agency V/s. Commissioner of Central Excise, Ahmedabad ORDER NOS. A/807/WZB/AHD of 2012 & S/944/WZB/AHD of 2012 APPLICATION NO. ST/S/782 OF 2011 APPEAL NO. ST/380 OF 2011 JUNE 5, 2012 ORDER M. V. Ravindran, Judicial Member This stay petition is filed for the waiver of pre-deposit of amount of service tax of Rs. 53,91,867/- with interest and penalties imposed under Section 76 of the Finance Act, 1994. 2. The issue involved in this appeal is regarding service tax liability on the appellant under the category of ‘...