𝗖𝗘𝗦𝗧𝗔𝗧 𝗔𝗵𝗺𝗲𝗱𝗮𝗯𝗮𝗱 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗟𝗶𝗮𝗯𝗶𝗹𝗶𝘁𝘆 𝗼𝗳 𝗖𝗵𝗮𝗿𝗶𝘁𝗮𝗯𝗹𝗲 𝗧𝗿𝘂𝘀𝘁𝘀 📢 The Tribunal held: "The charitable trust did not qualify as a 'Commercial Training or Coaching Centre' for service tax purposes, and the extended period of limitation cannot be invoked."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗖𝗼𝗺𝗽𝗮𝗻𝘆: Sophisticated Instrumentation, managed by Charutar Vidya Mandal, a public charitable trust. 𝗜𝘀𝘀𝘂𝗲: Does the appellant qualify as a "Commercial Training or Coaching Centre," justifying service tax? 𝗔𝗰𝘁𝗶𝘃𝗶𝘁𝘆: Provided training to students in science and technology but did not pay service tax, believing they were not a commercial training center.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The Tribunal ruled that due to ambiguity before 2010 regarding what qualifies as a "Commercial Training or Coaching Centre," the appellant, a charitable trust, reasonably believed they were exempt from service tax. Consequently, invoking the extended limitation period was unjustified. The appeal was allowed on grounds of limitation.

𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: Sophisticated Instrumentation vs. C.C.E. & S.T.-Vadodara 𝗦𝗘𝗥𝗩𝗜𝗖𝗘 𝗧𝗔𝗫 𝗔𝗽𝗽𝗲𝗮𝗹 𝗡𝗼. 11477 of 2013 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 22 September 2023 📜 This ruling clarifies that charitable trusts with a reasonable belief of exemption are not subject to extended limitation for service tax.