Rwa service tax rebate limit circular

Hi All,
 
Under the mega exemption the govt allowed the RWA to exempt any amount upto Rs5000pm collected from residents from the service tax. However, in the jan 2014 circular it was clarified that if the amount goes above 5000pm, the enitre contribution is liable for service Tax.
 
Our RWA takes 5500pm from the residents but has not been taking service tax ( our yearly collection from all flats is ~4crore)
 
Now we have a notice from service tax department to pay ST, currently we are not event registered with ST department :(
 
Our CA is suggesting to pay ST only on the amount above 5000 i.e. 500 and claim ignorance on the jan 2014 circular, stating that the circular is for internal use and we as public are not liable for circulars. Is it possible ?
 
Can we escape ST on the entire amount by this way or will we be liable for penalty ?
 
Please help !
 
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any input on this will be hugely appreciated !

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