https://www.taxtmi.com/caselaws?id=769415 CESTAT Chennai held that extended limitation period under Section 73(1) of Finance Act, 1994 cannot be invoked without concrete evidence of willful suppression or fraud. The appellant, who provided manpower recruitment services from 2005-2007, was unaware of service tax liability and voluntarily paid tax with interest upon audit detection before show cause notice issuance. The tribunal found no evidence of deliberate evasion, noting that mere mechanical reproduction of statutory language insufficient to justify extended limitation. Penalties under Sections 77 and 78 were deemed unjustified given bona fide ignorance and voluntary compliance. Appeal disposed in favor of appellant. en-us Tue, 22 Apr 2025 00:00:00 +0530 Fri, 25 Apr 2025 08:53:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=769415 CESTAT Chennai held that extended limitation period under Section 73(1) of Finance Act, 1994 cannot be invoked without concrete evidence of willful suppression or fraud. The appellant, who provided manpower recruitment services from 2005-2007, was unaware of service tax liability and voluntarily paid tax with interest upon audit detection before show cause notice issuance. The tribunal found no evidence of deliberate evasion, noting that mere mechanical reproduction of statutory language insufficient to justify extended limitation. Penalties under Sections 77 and 78 were deemed unjustified given bona fide ignorance and voluntary compliance. Appeal disposed in favor of appellant. Case-Laws Service Tax Tue, 22 Apr 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=769415