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Pushpam Pharmaceuticals Company vs Collector Of Central Excise, Bombay on 28 March, 1995

Appellant has also relied on CESTAT, Chandigarh Final Order No. A/60167- 60177/2019 dated 22.02.2019 in which it was held that the appellants were under bonafide belief that they are not liable to pay service tax as they are entitled for benefit of exemption under notification no. 6/2005-ST dated 01.03.2005 and Notification No. 33/2012-ST dated 20.06.2012, therefore, they did not pay service tax. Moreover, there was confusion in the industry during the relevant period whether the appellants are liable to pay service tax or the MSO liable to pay service tax on their activity, in that circumstances, the benefit of doubt goes in favour of the appellants. Therefore, we hold that the extended period is not invokable. Learned Counsel for the appellant also relied on the judgment of Pushpam Pharmaceuticals Company Vs CCE, Bombay [1995 (78) ELT 401 (SC)], in which it was held that "where facts are known to both parties the omission by one to do what he might have done and not that he must have done, does not render it suppression".
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