𝗖𝗘𝗦𝗧𝗔𝗧 𝗡𝗲𝘄 𝗗𝗲𝗹𝗵𝗶 𝗥𝘂𝗹𝗶𝗻𝗴 𝗼𝗻 𝗦𝗲𝗿𝘃𝗶𝗰𝗲 𝗧𝗮𝘅 𝗼𝗻 𝗥𝗲𝗴𝗶𝘀𝘁𝗿𝗮𝘁𝗶𝗼𝗻 𝗙𝗲𝗲𝘀 𝗳𝗼𝗿 𝗕𝗮𝗻𝗸 𝗧𝗿𝗮𝗻𝘀𝗮𝗰𝘁𝗶𝗼𝗻𝘀 📢 𝗧𝗵𝗲 𝗧𝗿𝗶𝗯𝘂𝗻𝗮𝗹 𝗵𝗲𝗹𝗱: "Service tax cannot be proposed and confirmed under two different heads/categories for the same activity. Additionally, the extended period of limitation is not invokable for a government company without proper rebuttal of presumption."

🔍 𝗙𝗮𝗰𝘁𝘀: 𝗔𝗽𝗽𝗲𝗹𝗹𝗮𝗻𝘁: M/s. Central Registry of Securitisation, Asset Reconstruction and Security Interest of India (CERSAI) 𝗜𝘀𝘀𝘂𝗲: The tribunal held service tax demand invalid due to ambiguous classification and rejected extended limitation for lack of willful suppression.

⚖️ 𝗝𝘂𝗱𝗴𝗲𝗺𝗲𝗻𝘁: The tribunal ruled that the extended period of limitation was inapplicable as the appellant, a government entity, was presumed not to have willfully suppressed facts. Additionally, the demand was invalidated due to ambiguity in service classification, as the show cause notice failed to specify a single taxable category as required under Section 65A.

📜 𝗖𝗮𝘀𝗲 𝗜𝗻𝗳𝗼𝗿𝗺𝗮𝘁𝗶𝗼𝗻: 𝗧𝗶𝘁𝗹𝗲: M/s. Central Registry of Securitisation, Asset Reconstruction and Security Interest of India (CERSAI) vs. Principal Commissioner CGST, South Delhi 𝗦𝗘𝗥𝗩𝗜𝗖𝗘 𝗧𝗔𝗫 𝗔𝗣𝗣𝗘𝗔𝗟 𝗡𝗢. 51425 OF 2017 𝗢𝗿𝗱𝗲𝗿 𝗗𝗮𝘁𝗲: 10 April 2023 📜 This ruling reinforces the requirement for precise service classification in show cause notices and limits the use of the extended limitation period against government entities without sufficient evidence.