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TMI Blog2018 (9) TMI 1380X X X X Extracts X X X X X X X X Extracts X X X X ..... hat:- The appellant were duly registered with the department and were filing the ST-3 returns by showing payment of Service Tax on the value of the services as indicated in the contracts entered by them with the said Public Sector Undertaking. In such a scenario the appellant was entertaining a bona fide belief and there was no mala fide on their part so as to justifiably invoke the longer period ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... The appellants have entered into a contract with M/s.Anpara Thermal Power Station for providing repair and maintenance services. As per the contract entered into between the two, all the terms of contract indicated the value of services and the value of the goods to be used in the said services. Accordingly the appellant discharged their Service Tax liability on the value of the services indicated ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... at the period involved in all the appeals is from 2006/07 to 2010/11 and the show cause notice stands issued on 05.10.2011. He submits that that the services were being provided to a Public Sector Undertaking under a contract and inasmuch as the said contract bifurcated the value of the services as also the value of the goods to be used in the said services, they adopted the assessable value of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... nger period of limitation. Accordingly we hold that extended period is not available to the Revenue. However, as a part of demand falls within the limitation period we direct the adjudicating authority to re-quantify the demands against all the appellants for which purpose, the matter is remanded to him. 6. As we have already concluded that there was no mala fide on the part of the assesses we ..... X X X X Extracts X X X X X X X X Extracts X X X X
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