Judgment :

I. Mahanty, J. In the present writ application, challenge has been made to the demand-cum-show cause notice dated 22.9.2014 under Annexure13 on the basis of the assertion that the petitioner-Bhubaneswar Development Authority (B.D.A.) which has registered under the Service Tax Act for providing “Renting of Immovable Property Services”, classifiable under erstwhile Section 65(105)(zzzz) read with Section 65(66) and 65(67) of the Finance Act, 1994 and thereafter, under Section 66-E of the Act and calling upon to submit their show-cause within 30 days of the receipt of the notice as to why service tax interest/penalty shall not be levied.

2. Mr.G.Mukherji, learned counsel for the petitioner has sought to challenge the issue of demand-cum-show cause notice under Annexure-13, inter alia, essentially on the ground that the conditions precedent for exercise of jurisdiction to invoke the extended period of limitation are wholly absent and the Commissioner has not properly applied his mind to the question as to whether the condition for invoking the extended period of limitation existed and/or acted mechanically and consequently, he submits that the impugned show-cause notice amoun