The Appellate Tribunal held that the invocation of the extended...

The Appellate Tribunal held that the invocation of the extended period of limitation for raising Service Tax demands was not sustainable, as the appellant had filed returns regularly and provided all requisite information to the Department. The Revenue failed to establish any suppression of facts with intent to evade tax. The Show Cause Notice, based on discrepancies between financial statements and returns but issued without category-wise quantification, was declared void ab initio. Consequently, the Service Tax demand confirmed in the impugned order was set aside as barred by limitation. Further, since the demand was not sustained, the imposition of interest and penalties was also quashed. The appeal was allowed, resulting in the complete dismissal of the tax demand, interest, and penalties.