https://www.taxtmi.com/caselaws?id=446755 An approved flying training institute operating under the Aircraft Rules, 1937 and Civil Aviation Requirements, and supervised by the DGCA, issues course completion certificates that retain legal recognition even if a further DGCA examination is required for the final licence; the 11.05.2011 Instruction could not override that statutory scheme, so the service tax demand founded on it was unsustainable. A notice invoking only the normal limitation period under Section 73(1) of the Finance Act, 1994 could not be extended absent fraud, collusion, wilful misstatement, or suppression of facts; the demand beyond eighteen months was therefore time-barred. en-us Tue, 31 Oct 2023 00:00:00 +0530 Fri, 12 Sep 2025 14:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446755 An approved flying training institute operating under the Aircraft Rules, 1937 and Civil Aviation Requirements, and supervised by the DGCA, issues course completion certificates that retain legal recognition even if a further DGCA examination is required for the final licence; the 11.05.2011 Instruction could not override that statutory scheme, so the service tax demand founded on it was unsustainable. A notice invoking only the normal limitation period under Section 73(1) of the Finance Act, 1994 could not be extended absent fraud, collusion, wilful misstatement, or suppression of facts; the demand beyond eighteen months was therefore time-barred. Case-Laws Service Tax Tue, 31 Oct 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446755