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Commissioner Of Central Excise, Mumbai vs Mahindra And Mahindra Ltd. on 1 September, 2004

4. Ld. DR reiterates the findings of the lower authority and asserts that the demands were correctly confirmed and penalties were correctly imposed. He also argues that merely because the assessee is entitled to CENVAT Credit, it does not mean that extended period of limitation cannot be invoked, as has been held by Hon'ble Apex Court in the case of Commissioner of Central Excise, Mumbai vs. Mahindra & Mahindra Limited [2005(179) ELT 21 (S.C.)].
Supreme Court of India Cites 2 - Cited by 10 - Full Document

Indian National Shipowners Assn. vs Union Of India . on 27 January, 2016

3. Ld. Counsel for the appellant submits that it is now well settled that the demand of service tax on the services received from abroad under reverse charge mechanism cannot be upheld for the period prior to 18.04.2006 when Section 66A was inserted in the Finance Act, 1994. This issue has been settled in the case of Indian National Shipowners' Association vs. Union of India [2009(14)S.T.R. 289 (Bom.)]. Hence the demand for the period upto 18.04.2006 needs to be set aside. His second round of argument is that the extended period of limitation cannot be invoked even for the period post 18.04.2006 because there is no evidence of intention to evade payment of service tax. In fact, if they had paid the service tax, they were entitled to avail CENVAT Credit of the same amount. Therefore, as far as they are concerned, the entire exercise is revenue neutral and hence (3) Appeal No. ST/3167/2011 extended period of limitation alleging fraud, collusion, wilful misstatement cannot be invoked. For the same reason, no penalty should be imposed under section 78 because the elements necessary for imposing the penalty are absent.
Supreme Court - Daily Orders Cites 0 - Cited by 70 - Full Document
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