S. S. GARG :

The present appeal is directed against the impugned Order-in-Appeal dated 30.08.2019 passed by the Commissioner (Appeals), CGST, Gurugram, whereby the learned Commissioner (Appeals) has confirmed the demand partially by invoking the extended period of limitation.

2. Briefly stated facts of the present case are that the Appellant is registered with the Service Tax department for providing taxable services of ‘Information Technology Software Service’ as specified under Section 65(105)(zzzze) of the Finance Act, 1994. Audit of the Appellant’s records was conducted by the department on 09.02.2018 & 28.02.2018 for the period 2012-13 to 2014-15 and certain discrepancies were observed by the audit team. On the basis of those discrepancies, a Show Cause Notice dated 23.08.2018 was issued to the Appellant by invoking the extended period of limitation. The Appellant contested the allegations made in Show Cause Notice and filed detailed reply to all the allegations raised in the Show Cause Notice. After following the due process, the Adjudicating Authority vide Order-in-Original dated 05.02.2019, confirmed the demands of Rs.44,73,582/- & Rs.49,868/- under proviso to Section 73(1)