https://www.taxtmi.com/caselaws?id=446996 Extended limitation for service tax cannot be invoked absent cogent evidence of suppression, wilful misstatement, fraud, or deliberate withholding of facts, particularly where the dispute is interpretational and the assessee maintained audited books and filed returns. Here, construction of a mechanised fertiliser handling and bagging facility in the port backup area was treated as a port-related activity, and the record did not show any positive act of evasion. The demand was therefore barred by limitation, and the service tax demand and impugned order were set aside with consequential relief. en-us Thu, 14 Dec 2023 00:00:00 +0530 Thu, 14 Dec 2023 18:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446996 Extended limitation for service tax cannot be invoked absent cogent evidence of suppression, wilful misstatement, fraud, or deliberate withholding of facts, particularly where the dispute is interpretational and the assessee maintained audited books and filed returns. Here, construction of a mechanised fertiliser handling and bagging facility in the port backup area was treated as a port-related activity, and the record did not show any positive act of evasion. The demand was therefore barred by limitation, and the service tax demand and impugned order were set aside with consequential relief. Case-Laws Service Tax Thu, 14 Dec 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446996