Commercial Training and Coaching Service: Amendment had taken place only after the disputed period in the appeal. There is no provision for applying the said changes retrospectively. Further, a part of the demand relates to inclusion of Mess charges. By no stretch of imagination, the Mess charges collected can be considered as receipt for rendering the service of ‘Commercial Training and Coaching'.

Limitation: Extended Period: Further we find that the show cause notices was issued based on some Audit objection. There is no justification for invoking the longer period. Therefore, the demand is also hit by time bar. Appeal allowed.

Audit Enquiry: Limitation: Audit Enquiry and the Audit Note clearly disclose the fact of the appellants having disclosed all the facts. There is no finding pertaining to any suppression of facts leading to recovery for larger period. Stay application is allowed.