M/S. Turret Industrial Security ... vs Coms,C.Ex - Jsr on 22 October, 2019
10. Taking note of the above amendment, the Hon'ble Chhattisgarh
High Court in Engineers India Technical Services (Supra), observed
that the amendment in Section 73 by way of insertion of sub section
(2A) is introduced only w.e.f. 10.05.2013 long after the period in
dispute involved in the said case could not help the case of
department. Only implication that can be derived is that the show
cause notice issued for extended period could not be converted into
notice for demand of service tax for shorter / normal period of
limitation. The relevant portion of the High Court decision is as below-