Extended limitation for service tax applies where suppression of taxable cleaning services and intent to evade are established.

Wilful suppression of taxable cleaning services justified invocation of the extended limitation period where the assessee had neither registered nor paid service tax nor filed ST-3 returns, and the non-disclosure was discovered only through departmental inquiry. The demand was therefore not time-barred, because departmental awareness did not defeat the statutory extended period once intent to evade tax was established. Consequential interest and penalties were also sustained, as the finding of suppression barred waiver of penalty.

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Issues: Whether the extended period of limitation was invocable on the ground of suppression of facts, and whether the demand and penalties for non-payment of service tax on cleaning services were sustainable.

Analysis: The appellant was found to have provided cleaning services without registration, without payment of service tax, and without filing ST-3 returns. The non-payment came to light only after departmental inquiry, and the failure to disclose the taxable activity was treated as suppression of material facts. The contention that the demand was barred by limitation was rejected, since knowledge of the department does not by itself extinguish the statutory extended period where wilful suppression with intent to evade tax is established. The plea for penalty waiver was also not accepted in view of the finding of suppression.

Conclusion: The extended period of limitation was rightly invoked, and the demand with consequential interest and penalties was sustained against the appellant.

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