Extended limitation requires intent to evade; disputed intermediary-service classification restricted service tax recovery to the normal period.

Extended limitation for recovery of service tax on intermediary services requires deliberate suppression, wilful misstatement, or contravention with intent to evade tax; mere non-disclosure or omission is insufficient. Because classification of intermediary services was disputed and interpreted differently during the relevant period, failure to pay tax under a bona fide belief could not amount to wilful suppression or intentional evasion. The demand was therefore restricted to the normal limitation period, with applicable interest.

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Issues: Whether the extended period of limitation could be invoked for recovery of service tax on intermediary services.

Analysis: Invocation of the extended period requires deliberate suppression, wilful misstatement, or contravention with intent to evade tax; mere non-disclosure or omission is insufficient. The classification of intermediary services was disputed during the relevant period and had been interpreted differently over time. The assessee's failure to discharge tax under a bona fide belief therefore could not be treated as wilful suppression or intentional evasion.

Conclusion: The extended period of limitation was not invocable; the demand could be sustained only for the normal period with applicable interest, in favour of the assessee.

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