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    <title>2025 (11) TMI 1554 - CESTAT ALLAHABAD</title>
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    <description>CESTAT Allahabad allowed the appeal, setting aside the service tax demand of Rs. 53,390/-, which had been raised on the basis of differences between ST-3 returns and Form 26AS/TDS data by invoking the extended period of limitation. Relying on the SC judgment in Pushpam Pharmaceuticals and a coordinate bench decision in G. D. Goenka Pvt. Ltd., the Tribunal held that extended limitation was not available in the absence of willful suppression. As the demand itself was unsustainable, penalties imposed under sections 77 and 78 were also quashed, and the appeal was allowed both on merits and on limitation.</description>
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    <pubDate>Thu, 20 Nov 2025 00:00:00 +0530</pubDate>
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      <title>2025 (11) TMI 1554 - CESTAT ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=782086</link>
      <description>CESTAT Allahabad allowed the appeal, setting aside the service tax demand of Rs. 53,390/-, which had been raised on the basis of differences between ST-3 returns and Form 26AS/TDS data by invoking the extended period of limitation. Relying on the SC judgment in Pushpam Pharmaceuticals and a coordinate bench decision in G. D. Goenka Pvt. Ltd., the Tribunal held that extended limitation was not available in the absence of willful suppression. As the demand itself was unsustainable, penalties imposed under sections 77 and 78 were also quashed, and the appeal was allowed both on merits and on limitation.</description>
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