https://www.taxtmi.com/caselaws?id=786138 Demand based solely on Income Tax records/Form 26AS is unsustainable for lack of independent corroboration; accordingly the assessment confirmed on that basis is set aside. The impugned order failed to determine taxable value transactionwise under Section 67, rendering the demand legally invalid, and Rs.20,39,712 is held refundable. Invocation of the extended limitation period is unjustified where facts derive from statutory records, so the demand is timebarred. Interest and penalty under Section 78 are set aside as the foundational demand is unsustainable, but penalty for nonfiling of returns under Section 77 is upheld. en-us Thu, 15 Jan 2026 00:00:00 +0530 Sat, 07 Feb 2026 07:19:06 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786138 Demand based solely on Income Tax records/Form 26AS is unsustainable for lack of independent corroboration; accordingly the assessment confirmed on that basis is set aside. The impugned order failed to determine taxable value transactionwise under Section 67, rendering the demand legally invalid, and Rs.20,39,712 is held refundable. Invocation of the extended limitation period is unjustified where facts derive from statutory records, so the demand is timebarred. Interest and penalty under Section 78 are set aside as the foundational demand is unsustainable, but penalty for nonfiling of returns under Section 77 is upheld. Case-Laws Service Tax Thu, 15 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786138