Service tax limitation and composite demand rules require wilful suppression proof and clear, segregated allegations before liability is fixed.

Extended limitation under service tax requires proof of wilful suppression or deliberate intent to evade tax; mere non-disclosure is insufficient. The notes also state that composite demands must be supported by clear, segregated allegations and record-based quantification: sponsorship service demand failed where tax had already been paid on the relevant component, inter-company short-payment and interest demands failed for lack of a specific breakup, and the renting issue could not be reopened without proper appreciation of the material. Import of services and software licence fee issues were directed for de novo examination of documents, contracts, and the appellant's role before liability could be fixed.

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Issues: (i) whether the extended period of limitation was invocable; (ii) whether the demand under sponsorship services was sustainable; (iii) whether the demands for inter-company service short payment, interest, renting of immovable property, import of services and software licence fee were sustainable.

Issue (i): whether the extended period of limitation was invocable.

Analysis: The record did not disclose any substantial finding showing wilful suppression or any positive act of concealment. Mere non-disclosure, without proof of deliberate intent to evade tax, was held insufficient for invoking the longer limitation period.

Conclusion: The extended period of limitation was not invocable and the demand beyond the normal period was unsustainable.

Issue (ii): whether the demand under sponsorship services was sustainable.

Analysis: The expenses were found to have been clubbed together without proper segregation of their nature or consideration of whether service tax had already been discharged by the service providers. The actual sponsorship expenditure was treated as materially lower than the figure adopted in the adjudication order, and the appellant had already discharged tax on the sponsorship component under reverse charge.

Conclusion: The demand under sponsorship services was unsustainable and was set aside.

Issue (iii): whether the demands for inter-company service short payment, interest, renting of immovable property, import of services and software licence fee were sustainable.

Analysis: For the alleged inter-company short payment and the interest demand, the absence of a specific breakup or clear allegation in the notice and order rendered the demands unsustainable. For renting of immovable property, the matter had already been settled, and the adjudication was found to have reopened the issue without properly appreciating the material and the appellant's opportunity to establish payment. For import of services and software licence fee, the Tribunal found the matter required fresh examination of the documents, contracts, and the appellant's role before any liability could be fixed.

Conclusion: The inter-company short payment and interest demands were unsustainable, the renting demand was set aside, and the issues relating to import of services and software licence fee were remanded for de novo adjudication.

Final Conclusion: The appellant obtained substantial relief: the time-bar objection succeeded, the sponsorship demand and certain ancillary demands were annulled, and the remaining disputed service tax issues were sent back for fresh consideration on the normal period basis.

Ratio Decidendi: Invocation of the extended limitation period requires proof of wilful suppression or deliberate intent to evade tax, and composite service-tax demands must rest on clear, segregated allegations supported by the record.

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