Penalty u/s 78 of the FA, 1994 - appellant had correctly advised not to challenged the invocation of the...

Penalty u/s 78 of the FA, 1994 - appellant had correctly advised not to challenged the invocation of the extended period of limitation for recovery of service tax though the parameters/conditions for imposing equivalent penalty u/s 78 is same - appellant after having recovered the service tax from its customer had not paid over the amount to the State clearly point to mala fide conduct - penalty upheld .....

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