Extended limitation unavailable without suppression of facts; demand, interest and penalties for computer training services were set aside.

The dispute concerned whether exemption notifications for computer training services applied and, more importantly, whether the extended limitation period could be used absent suppression of facts or contumacious conduct. The Tribunal found no material showing intent to evade tax and held that the extended period was not invocable. As a result, the demand, interest and penalties were set aside and consequential relief was granted.

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Issues: Whether the extended period of limitation was invocable in the absence of suppression of facts or contumacious conduct, and whether the demand, interest and penalties could be sustained.

Analysis: The dispute turned on an interpretational issue concerning exemption notifications applicable to computer training services. On the facts, the Tribunal found no material to establish suppression of facts with intent to evade tax, nor any contumacious conduct by the appellant. In such circumstances, the extended period of limitation could not be invoked.

Conclusion: The extended period of limitation was not attracted. The demand, interest and penalties were set aside and consequential relief was granted.

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