Extended limitation fails where the Department already knew the facts and no suppression of transactions was shown.

The extended period of limitation could not be invoked for the service tax demand because the Department had already been informed of the ATM-related transactions through the audit questionnaire, the assessee's reply and supporting invoices well before the show cause notice. The dispute arose, at most, from non-production of original invoices, not from suppression of facts or fraud. Since the Department had knowledge of the relevant facts in 2013, the later notice in 2016 could not rely on the larger limitation period. The demand was therefore time-barred.

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Issues: Whether the extended period of limitation could be invoked for the service tax demand in the absence of suppression of facts by the assessee.

Analysis: The credit related to ATM machines purchased in 2011, and the Department had been informed of the transactions through the audit questionnaire, the assessee's reply, and the supporting invoices well before issuance of the show cause notice. The records showed that the dispute, at its highest, arose from non-production of original invoices and not from concealment of the transactions. Once the Department had knowledge of the relevant facts in 2013, the later show cause notice in 2016 could not rest on suppression or fraud, and the attempt to invoke the larger period amounted only to a change of opinion.

Conclusion: The extended period of limitation was not available to the Revenue and the demand was time-barred.

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