https://www.taxtmi.com/caselaws?id=766626 Extended limitation under the first proviso to Section 73(1) of the Finance Act, 1994 could not be invoked where alleged wilful suppression rested on the same controversy already raised in earlier notices and departmental adjudication. Because those proceedings had already disclosed the taxpayer's stand, the factual foundation for suppression and intent to evade was absent. Mere non-response to some notices was insufficient, especially since the department could proceed ex parte or by best judgment. A bare repetition of statutory language did not establish the required intent, so the show cause notice was unsustainable. en-us Mon, 03 Feb 2025 00:00:00 +0530 Sat, 01 Mar 2025 08:25:43 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766626 Extended limitation under the first proviso to Section 73(1) of the Finance Act, 1994 could not be invoked where alleged wilful suppression rested on the same controversy already raised in earlier notices and departmental adjudication. Because those proceedings had already disclosed the taxpayer's stand, the factual foundation for suppression and intent to evade was absent. Mere non-response to some notices was insufficient, especially since the department could proceed ex parte or by best judgment. A bare repetition of statutory language did not establish the required intent, so the show cause notice was unsustainable. Case-Laws Service Tax Mon, 03 Feb 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766626