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TMI Blog2017 (9) TMI 1322X X X X Extracts X X X X X X X X Extracts X X X X ..... ere duly reflected in their statutory records and law on the issue was also clear. As such, this is a fit case for granting relief under section 80 of the FA, 1994 - Further, the provisions of section 73 (1A) also is to be made applicable - penalty set aside - appeal allowed - decided in favor of appellant. - ST/40321/2017 - Final Order No. 41169/2017 - Dated:- 6-7-2017 - Smt. Archana Wadhwa, M ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... payment of service tax on reverse charge basis during the relevant period was subject-matter of litigation before various authorities and the law was not clear. The appellants being a small manufacture and exporter of their final product was not aware of the legal provisions and as such could not pay the service tax. As soon as they came to know about their liability to pay service tax, the same ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... sions of the Tribunal on the said issue. 4. After hearing the learned departmental representative, I find that confirmation of demand and interest is not being challenged. The same is accordingly being confirmed. As regards penalty, I find that the appellants were entertaining a bona fide belief and no malafide can be attributed to them as the receipt of GTA services were duly reflected in the ..... X X X X Extracts X X X X X X X X Extracts X X X X
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