Held - The appellant have maintained proper records of its transactions and turnover. They have also filed their IT-returns. Further, the appellant had admittedly taken suo moto registration under Service tax provision. In the circumstances, I find that there is no suppression or failure on the part of the appellant to make compliance under the service tax provisions. Rather revenue have chosen to not make any enquiry for the period prior to 0.....

Held - It has merely stated that the fact of non-payment would not come to notice but for the verification of the audit department. In the absence of any specific allegation and proof that the appellant has suppressed facts, the extended period cannot be invoked. There is no evidence adduced by the department that the appellant has suppressed facts with intent to evade payment of duty. The decisions relied by the learned counsel in the case of.....