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Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within normal limitation.
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Service-tax show cause notices based on foreign-currency expenditure remain valid where they identify the alleged services sufficiently for the assessee to provide service-wise and amount-wise replies; further elaboration during adjudication does not exceed the notices' scope. Extended limitation cannot rest on a bare statutory reference without pleaded facts showing fraud, collusion, wilful misstatement or suppression with intent to evade tax, particularly after an earlier audit-based notice and where employee secondment involves interpretive issues. Overseas employee secondment constitutes manpower supply, subject only to the normal limitation period. Other service-tax demands require fresh reasoned determination after considering submissions, accounting evidence, the Chartered Accountant certificate, and relevant accounting standards and procedures.
Service-tax show cause notices based on foreign-currency expenditure remain valid where they identify the alleged services sufficiently for the assessee to provide service-wise and amount-wise replies; further elaboration during adjudication does not exceed the notices' scope. Extended limitation cannot rest on a bare statutory reference without pleaded facts showing fraud, collusion, wilful misstatement or suppression with intent to evade tax, particularly after an earlier audit-based notice and where employee secondment involves interpretive issues. Overseas employee secondment constitutes manpower supply, subject only to the normal limitation period. Other service-tax demands require fresh reasoned determination after considering submissions, accounting evidence, the Chartered Accountant certificate, and relevant accounting standards and procedures.
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