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    <title>2025 (2) TMI 1055 - CESTAT CHANDIGARH</title>
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    <description>Service tax demand could not be sustained by invoking the extended period because suppression of facts with intent to evade tax was not established. The assessee, a Government of India undertaking, had disclosed the activity, and the department had knowledge through audits and repeated correspondence during the relevant period. The original authority&#039;s finding that no mala fide intention to evade tax could be inferred had attained finality, leaving no basis for extended limitation. The demand was therefore barred by limitation, and the appeal succeeded without examination of the merits.</description>
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      <description>Service tax demand could not be sustained by invoking the extended period because suppression of facts with intent to evade tax was not established. The assessee, a Government of India undertaking, had disclosed the activity, and the department had knowledge through audits and repeated correspondence during the relevant period. The original authority&#039;s finding that no mala fide intention to evade tax could be inferred had attained finality, leaving no basis for extended limitation. The demand was therefore barred by limitation, and the appeal succeeded without examination of the merits.</description>
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