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TMI Blog2018 (7) TMI 1719X X X X Extracts X X X X X X X X Extracts X X X X ..... date was extended repeatedly from 25th October, 2011 to 6/01/2012 - the relevant date is to be considered as 06/01/2012 and hence even within the normal time limit of 18 months, the demand covering the period April to September 2011 will also get included in the demand - appeal allowed - decided in favor of Revenue. - Appeal No. ST/51721/2017-SMC - A/52544/2018-SM[BR] - Dated:- 17-7-2018 - Mr. ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... show cause notice dated 31/05/2013 raising demand for Service Tax for the period 01/04/2008 to 31/03/2012. The show cause notice was adjudicated with the issue of impugned order dated 02/01/2017. In the impugned order the adjudicating authority took the view that this was not a fit case for invoking the extended period of limitation in terms of proviso to Section 73(1) of the Finance Act, 1994. B ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... e Ld. DR for Revenue. 4. The Ld. DR submitted that the Revenue s appeal is on a limited ground. The normal time limit under Section 73(1) of the Finance Act, 1994, which is a period of 18 months, is to be calculated from the relevant date . The relevant date is the date on which the ST-3 Return is to be filed. For the period April to September 2011, the due date for filing such return is norma ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... notice dated 31/05/2013, to that falling within the normal time limit under Section 73 (1). While Revenue has no grievance on this finding, it has been urged that the demand falling within the normal time limit of 18 months is to be reckoned from the relevant date. The due date for filing ST-3 becomes the relevant date and in the case of the ST-3 Return due for the period April to September, 2011, ..... X X X X Extracts X X X X X X X X Extracts X X X X
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