Revenue Neutrality in Service Tax Matter: CESTAT quashes Invocation of Extended Period of Limitation

CESTAT quashed the invocation of the extended period of limitation in a Service Tax case, citing the principle of revenue neutrality. The Tribunal held that if there is no net gain or loss to the revenue, the extended period cannot be invoked for tax recovery. This decision reinforces the principle that extended limitations should only apply in cases of fraud or wilful misrepresentation and not when the tax impact is neutral.