(1.) HEARD both sides.
(2.) REVENUE filed this Appeal against the Order -in -Appeal whereby part of the demand was set aside as time -barred. The present proceedings were initiated in pursuance of a show -cause notice issued to the respondents for imposition of penalty under Sections 76 and 77 of Chapter V of the Finance Act, 1994.
(3.) THE contention of the respondents is that in the year, 1998, the respondents applied for their registration and ultimately, they were registered with the authorities concerned as a provider of taxable service. Their contention is that the show -cause notice was issued to the respondents for imposition of penalties only. Therefore, under this show -cause notice, the demand is not sustainable.