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    <description>Extended limitation under the Finance Act, 1994 can be invoked only on proof of fraud, collusion, wilful misstatement, suppression of facts, or deliberate contravention with intent to evade service tax. On the facts noted, the bank had maintained separate accounts, was newly subject to service tax compliance, and had furnished branch-wise details; the lapse was treated as technical and reasonable cause was found for delayed return filing. As a result, the extended period was unavailable to the Revenue and the penalty-based demand could not be sustained.</description>
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