Whether ignorance of law can be a factor for not to revoke extended period of limitation?

19 - Demand and Recovery

Yes. In the case of R Deivendran [2009 (1) TMI 68 - CESTAT, CHENNAI], it was held that the appellant herein is claimed to be an illiterate person and had rented a vehicle to M/s. BSNL for its staff to compute between their respective residences and the office. The lower authorities have found the service tax of ₹ 9,080/- payable by the appellant as he had wilfully suppressed the fact of rendering taxable service. I find that there is nothing on record to substantiate the above finding. The claim that such an allegation had not been made in the show-cause notice is also not contested. In the circumstances I find that the demand of service tax and the penalties adjudged in the impugned order are not sustainable. 

Dated: 3-4-2015