https://www.taxtmi.com/caselaws?id=784399 The dominant issue was whether the extended period of limitation could be invoked to recover service tax, interest and penalty on reimbursable amounts collected where the assessee claimed "pure agent" status. The Tribunal held that the dispute turned on interpretation of the "pure agent" provisions under the Finance Act, 1994 and rules, and the assessee acted under a bona fide belief; further, the SCN contained no specific averments of suppression, misstatement, or intent to evade, as required to trigger the extended period. Applying SC and HC precedent that mere interpretational disputes and absence of pleaded mala fides bar the extended period, the demand was held time-barred; the impugned order was set aside and the appeal allowed. en-us Tue, 02 Dec 2025 00:00:00 +0530 Fri, 02 Jan 2026 18:02:58 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=784399 The dominant issue was whether the extended period of limitation could be invoked to recover service tax, interest and penalty on reimbursable amounts collected where the assessee claimed "pure agent" status. The Tribunal held that the dispute turned on interpretation of the "pure agent" provisions under the Finance Act, 1994 and rules, and the assessee acted under a bona fide belief; further, the SCN contained no specific averments of suppression, misstatement, or intent to evade, as required to trigger the extended period. Applying SC and HC precedent that mere interpretational disputes and absence of pleaded mala fides bar the extended period, the demand was held time-barred; the impugned order was set aside and the appeal allowed. Case-Laws Service Tax Tue, 02 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=784399