https://www.taxtmi.com/caselaws?id=785097 Extended limitation under the proviso to Section 73(1) cannot be invoked where the taxable persons records were audited and short payments were previously adjudicated, because absence of suppression, fraud, collusion or wilful misstatement negates the factual basis for invoking the proviso; consequence: subsequent show cause notice and demand are time-barred and penalties are not warranted. Discrepancies between income-tax returns and ST-3 returns, without concealment, do not convert audit lacunae into grounds for extended limitation, and prior audit/adjudication precludes fresh demands under the extended period. en-us Thu, 15 Jan 2026 00:00:00 +0530 Sat, 17 Jan 2026 08:45:27 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785097 Extended limitation under the proviso to Section 73(1) cannot be invoked where the taxable persons records were audited and short payments were previously adjudicated, because absence of suppression, fraud, collusion or wilful misstatement negates the factual basis for invoking the proviso; consequence: subsequent show cause notice and demand are time-barred and penalties are not warranted. Discrepancies between income-tax returns and ST-3 returns, without concealment, do not convert audit lacunae into grounds for extended limitation, and prior audit/adjudication precludes fresh demands under the extended period. Case-Laws Service Tax Thu, 15 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785097