Extended limitation requires intentional suppression; disclosed weighbridge receipts and a bona fide interpretive mistake rendered the service-tax demand time-barred.

Extended limitation for recovery of service tax on weighbridge-service receipts cannot be invoked where the assessee was registered, regularly filed returns, paid tax on other taxable services, and recorded the receipts in its financial records. The material did not establish suppression of facts with intent to evade tax; the non-payment was treated as a bona fide mistake in a dispute involving legal interpretation and detected during audit. The service-tax demand was therefore time-barred.

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Issues: Whether the extended period of limitation could be invoked for recovery of service tax on weighbridge-service receipts.

Analysis: The assessee was registered, regularly filed service-tax returns, discharged tax on other taxable services, and recorded the weighbridge receipts in its financial records. No material established that the non-payment arose from anything other than a bona fide mistake or that it involved suppression of facts with intent to evade tax. The matter was detected during audit, and the dispute involved legal interpretation.

Conclusion: Invocation of the extended limitation period was invalid; the demand was time-barred.

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