https://www.taxtmi.com/caselaws?id=757399 Extended limitation for service tax could not be invoked where the demand rested mainly on 26AS data and sample invoices, and the Department failed to conduct adequate verification of the assessee's address, records, or the nature of services rendered. Mere third-party financial data, without meaningful inquiry or corroborative evidence, was insufficient to sustain a best judgment assessment. The record also disclosed no positive material showing wilful suppression, misstatement, or intent to evade tax, which are necessary to justify the extended period. As a result, the demand and penalties could not be sustained on limitation, while the merits were left undecided. en-us Thu, 22 Aug 2024 00:00:00 +0530 Sat, 24 Aug 2024 09:04:22 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757399 Extended limitation for service tax could not be invoked where the demand rested mainly on 26AS data and sample invoices, and the Department failed to conduct adequate verification of the assessee's address, records, or the nature of services rendered. Mere third-party financial data, without meaningful inquiry or corroborative evidence, was insufficient to sustain a best judgment assessment. The record also disclosed no positive material showing wilful suppression, misstatement, or intent to evade tax, which are necessary to justify the extended period. As a result, the demand and penalties could not be sustained on limitation, while the merits were left undecided. Case-Laws Service Tax Thu, 22 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757399