https://www.taxtmi.com/caselaws?id=465530 Extended limitation and penalties for service tax on secondment of employees and allied taxable services were in issue. Relying on SC's ruling in Northern Operating Systems, the Tribunal held that the long-standing controversy on secondment negated any inference of wilful suppression or deliberate misstatement; consequently, invocation of the extended period and section 78 penalty was legally unsustainable, and recovery was confined to the normal period only, with all demands beyond that dropped. For other admitted taxable activities, including "network communication", the appellant failed to justify restricting tax to administrative mark-up; therefore, tax for the four recoverable heads was limited to the normal period as to be computed by the Department, with penalty confined to section 76. Appeal allowed. en-us Thu, 30 Jan 2025 00:00:00 +0530 Tue, 30 Dec 2025 19:04:30 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=465530 Extended limitation and penalties for service tax on secondment of employees and allied taxable services were in issue. Relying on SC's ruling in Northern Operating Systems, the Tribunal held that the long-standing controversy on secondment negated any inference of wilful suppression or deliberate misstatement; consequently, invocation of the extended period and section 78 penalty was legally unsustainable, and recovery was confined to the normal period only, with all demands beyond that dropped. For other admitted taxable activities, including "network communication", the appellant failed to justify restricting tax to administrative mark-up; therefore, tax for the four recoverable heads was limited to the normal period as to be computed by the Department, with penalty confined to section 76. Appeal allowed. Case-Laws Service Tax Thu, 30 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=465530