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2015 (2) TMI 432

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..... refore, we requested the Ld. A.R appearing for the Revenue to show us in which part of the order appealed against, this fact has been recorded or in which part of the show cause notice this fact is recorded. The ld. A.R fairly conceded that the fact of the ST-3 return having been filed on 28/03/2007 is neither mentioned in the order nor in the show cause notice. If that be so, Revenue cannot alleg .....

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..... ed 06/03/2014, where in para 5.5 of the order, it has been stated as follows:- 5.5 As regards the contention of the appellant with regard to time bar, there is some merit in this argument. The show-cause notice dated 15.11.2010 seeks to demand Service Tax for the period 1.4.2005 onwards i.e. even beyond the extended period of 5 years. Therefore, the demand for the period 1.4.2005 to 30.9.2005 f .....

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..... of the return by the appellant on 28/03/2007 has been recorded anywhere. Therefore, we requested the Ld. A.R appearing for the Revenue to show us in which part of the order appealed against, this fact has been recorded or in which part of the show cause notice this fact is recorded. The ld. A.R fairly conceded that the fact of the ST-3 return having been filed on 28/03/2007 is neither mentioned in .....

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