Service tax scn limitation period

Some one pls clear my doubt. Its urgent.

Notice Subject ?

Service Tax Notice alleging that we have  provided sponsorship service to CSK and Kings Eleven Punjab but in actual we have only done promotional activity

As per the provisions of Section 73(1) of Finance Act, 1994, the show cause notice is to be issued within 18 months from the relevent date.

Relevent date is the due date or date of filing the ST-3 return.

In the instant case the ST-3 return for April,2014 to Sept,2014 was filed/due date on 25.10.2014. Thus the period of limitation of 18 months starts from 25.10.2014, and the last date for issue of Show Cause notice to demand Service Tax for April, 2014 is 24.04.2016.

Since the notice in the instant case is issued on 13.04.2016 (received by assessee), the same is issued within the limitation period.