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CUSTOMS EXCISE & SERVICE TAX APPELLATE TRIBUNAL
S. S. Garg, Judicial Member
Airline Reservation System – Appellant
Versus
Commissioner of Central Goods & Service Tax, Jalandhar – Respondent
| Table of Content |
|---|
| 1. overview of facts leading to service tax demand and appeals process. (Para 1 , 2) |
| 2. arguments concerning time-bar limits and the validity of using income tax data for service tax demands. (Para 4 , 5) |
| 3. court's findings on the impermissibility of using itr/26as discrepancies as the sole basis for service tax demands and the strict requirements for invoking the extended period of limitation. (Para 6 , 7 , 8 , 9) |
The present appeal is directed against the impugned order dated 21.12.2023 passed by the Commissioner (Appeals), CGST, Chandigarh dismissing the appeal of the appellant and upheld the Order-in-Original dated 13.03.2023 and confirmed the demand of service tax of Rs. 97,954/- under Section 73, interest under Section 75 and penalties under Section 77 & 78 of the Finance Act, 1994.
2. Briefly the facts of the present case are that the appellant is working as an actor in television serials has been regularly filing ST-3 returns and paying service tax on receipt basis. During the financial year 2014-15, the appellant provided acting services exclusively to M/s. Shashi Sumeet Productions Private Limited, Mumbai and the said Production House deducted TDS on the pro
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