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M/S Continental Foundation Joint ... vs Commissioner Of Central ... on 29 August, 2007

In this regard, we note that the Hon'ble Supreme Court in the case of Continental Foundation Joint Venture v. CCE, Chandigarh12 held that when there is scope for doubt in the mind of an assessee on a particular issue, the longer limitation period, under proviso to Section 11A(1) cannot be invoked. In the instant case, it is apparent that the appellant was in doubt regarding the leviability of service tax on the said transactions as she was under the impression that she was simply selling the goods at a higher MRP. We are of the opinion that the ratio of this judgement is applicable to the facts of this case. Therefore, the extended limitation period of 5 years under proviso to Section 73(1) of 12 [2007 (216) E.L.T. 177 (S.C.)] 14 Service Tax Appeal No. 50731 Of 2019 the Finance Act, 1994 cannot be sustained. Accordingly, the penalty equivalent to duty is also set-aside.
Supreme Court of India Cites 2 - Cited by 182 - A Pasayat - Full Document

Collector Of Central Excise vs Bata (India) Ltd. on 20 July, 1987

"4. A reading of the aforesaid Section clearly indicates that the wholesale price which a charged is deemed to be the value for the purpose of levy of excise duty, but the element of excise duty, sales tax or other taxes which is included in the wholesale price is to be excluded in arriving at the excisable value. This Section has been so construed by this Court in Asstt. Collector of Central Excise and Ors. v. Bata India Ltd., [1996] 4 SCC 563, and it is thus clear that when cum-duty price is charged, then in arriving at the excisable value of the goods the element of duty which is payable has to be excluded. The Tribunal has, therefore, rightly proceeded on the basis that the amount realised by the respondent from the sale of scrap has to be regarded as a normal wholesale price and in determining the value on which excise duty is payable the element of excise duty which must be regarded as having been incorporated in the sale price, must be excluded. There is nothing to show that once the demand was raised by the Department, the respondent sought to recover the same from the purchaser of scrap. The facts indicate that after the sale transaction was completed, the purchaser was under no obligation to pay any extra amount to the seller, namely, the respondent. In such a transaction, it is the seller who takes on the obligation of paying all taxes on the goods sold and in such a case the said taxes on the goods sold are to be deducted under Section 4(4)(d)(ii) and this is precisely what has been directed by the Tribunal. There is also nothing to show that the sale price was not cum-duty.
Customs, Excise and Gold Tribunal - Delhi Cites 0 - Cited by 34 - Full Document
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