https://www.taxtmi.com/caselaws?id=785766 Reverse charge mechanism placed liability to pay service tax on the service recipient for manpower supply/security services; where tax is payable 100% by recipient the provider is not liable for recipients tax defaults. Revenue must prove fraud, collusion, wilful misstatement or suppression of facts to invoke the extended limitation under the proviso to Section 73(1); absent such proof and given appellants bona fide belief and documentary evidence that recipient discharged tax, the extended-period demand cannot be sustained. Commissioner (Appeals) failed to adjudicate this point; impugned demand set aside and appeal allowed. en-us Fri, 30 Jan 2026 00:00:00 +0530 Sat, 31 Jan 2026 08:55:14 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=785766 Reverse charge mechanism placed liability to pay service tax on the service recipient for manpower supply/security services; where tax is payable 100% by recipient the provider is not liable for recipients tax defaults. Revenue must prove fraud, collusion, wilful misstatement or suppression of facts to invoke the extended limitation under the proviso to Section 73(1); absent such proof and given appellants bona fide belief and documentary evidence that recipient discharged tax, the extended-period demand cannot be sustained. Commissioner (Appeals) failed to adjudicate this point; impugned demand set aside and appeal allowed. Case-Laws Service Tax Fri, 30 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=785766