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2023 (4) TMI 871

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..... . Patel Enterprises, had been stated - case of Revenue is that since a separate show cause notice had been issued to M/s. Patel Enterprise, a reply should have been filed and a representative should also have appeared on the date fixed - HELD THAT:- It is no doubt true that separate notices were issued to M/s. Patel Enterprises and M/s. Dee Vee Projects Ltd, but in view of the peculiar facts and .....

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..... vocate for the Appellant Shri Rajeev Kapoor, Authorized Representative of the Department ORDER This appeal seeks the quashing of the order dated September 22, 2022 passed by the Principal Commissioner confirming the demand of service tax amounting Rs.10,85,70,355/- with interest and penalty. 2. It transpires from the records that a notice dated October 22, 2018 was issued to the .....

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..... ng facts relating to M/s. Patel Enterprises, had been stated. Learned counsel fairly stated that though a separate reply should have been filed by M/s. Patel Enterprises and M/s. Patel Enterprises should also have appeared for hearing, but because of a bonafide belief that since a reply had been filed by M/s. Dee Vee Projects Ltd and a representative for M/s. Dee Vee Projects Ltd had appeared on t .....

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..... tment have been considered. 6. It is no doubt true that separate notices were issued to M/s. Patel Enterprises and M/s. Dee Vee Projects Ltd, but in view of the peculiar facts and circumstances of the case that the business of M/s. Patel Enterprises was taken over by M/s. Dee Vee Projects Ltd on April 01, 2013; the period involved in both the show cause notices is 2013-14 and 2014-15, similar a .....

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