https://www.taxtmi.com/caselaws?id=774083 CESTAT Delhi allowed the appeal, setting aside service tax demand based on difference between ST-3 returns and Form 26AS data. The tribunal held that department failed to prove consideration was received for services, as appellant claimed non-payment due to billing disputes. Revenue cannot raise demand solely on 26AS differences without examining reasons and establishing entire amount represents service consideration. Extended limitation period was wrongly invoked since appellant was registered, filing returns, and maintaining proper records, showing no suppression of facts. The show cause notice was time-barred and demand confirmation was improper. en-us Wed, 02 Jul 2025 00:00:00 +0530 Wed, 02 Jul 2025 16:28:01 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=774083 CESTAT Delhi allowed the appeal, setting aside service tax demand based on difference between ST-3 returns and Form 26AS data. The tribunal held that department failed to prove consideration was received for services, as appellant claimed non-payment due to billing disputes. Revenue cannot raise demand solely on 26AS differences without examining reasons and establishing entire amount represents service consideration. Extended limitation period was wrongly invoked since appellant was registered, filing returns, and maintaining proper records, showing no suppression of facts. The show cause notice was time-barred and demand confirmation was improper. Case-Laws Service Tax Wed, 02 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=774083