TMI Blog2017 (1) TMI 1026X X X X Extracts X X X X X X X X Extracts X X X X ..... received from the foreign company and discharging tax liability on the said services under Section 66A. During the scrutiny of their returns it was noticed that the appellant had discharged the service tax @ 10.3% viz. rate prevalent at the time of payment of service tax on the services received prior to 24.02.2009. Prior to 24.02.2009 the rate of service tax was 12.36%. Revenue demanded duty on t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... It was argued that there cannot be any intention to evade duty in such circumstances and therefore extended period could not have been invoked. The appellant also sought relief under Section 80 under alternate option. 3. Learned D.R. relied on the impugned order. 4. I have gone through the rival submissions. The appellant has argued that the duty paid by them was available as credit to them. It ..... X X X X Extracts X X X X X X X X Extracts X X X X
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