https://www.taxtmi.com/caselaws?id=775075 The CESTAT Allahabad held that the second SCN dated 08.10.2021 was unsustainable on limitation grounds. Both SCNs were issued based on third-party data from the Income Tax Department regarding differential values between IT returns and ST-3 returns for advertisement space sales. The tribunal found that since the appellant regularly filed ST-3 returns and all relevant facts were known to authorities from the first SCN, there was no suppression of facts warranting invocation of extended limitation period. The revenue's case relied entirely on third-party data, which could not justify the longer limitation period. The tribunal concluded that similar facts from the first SCN could not constitute fresh suppression, making the second demand time-barred and liable to be set aside. Appeal was allowed. en-us Fri, 18 Jul 2025 00:00:00 +0530 Sat, 19 Jul 2025 08:25:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=775075 The CESTAT Allahabad held that the second SCN dated 08.10.2021 was unsustainable on limitation grounds. Both SCNs were issued based on third-party data from the Income Tax Department regarding differential values between IT returns and ST-3 returns for advertisement space sales. The tribunal found that since the appellant regularly filed ST-3 returns and all relevant facts were known to authorities from the first SCN, there was no suppression of facts warranting invocation of extended limitation period. The revenue's case relied entirely on third-party data, which could not justify the longer limitation period. The tribunal concluded that similar facts from the first SCN could not constitute fresh suppression, making the second demand time-barred and liable to be set aside. Appeal was allowed. Case-Laws Service Tax Fri, 18 Jul 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=775075