https://www.taxtmi.com/caselaws?id=786873 Sale of space or time for internet advertising for the years under review is taxable, with limited cum tax relief applied for the earlier year. The decision clarifies that invocation of an extended limitation period for assessing service tax requires specific and positive material demonstrating fraud, collusion, wilful misstatement or suppression of facts; mere non payment or bona fide belief in non taxability is insufficient. On the facts, disclosure in the taxpayer's registration and absence of specific allegations meant the proviso could not sustain the extended period demand, so the extended period demand was quashed while taxability was affirmed. en-us Fri, 20 Feb 2026 00:00:00 +0530 Fri, 20 Feb 2026 16:50:18 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786873 Sale of space or time for internet advertising for the years under review is taxable, with limited cum tax relief applied for the earlier year. The decision clarifies that invocation of an extended limitation period for assessing service tax requires specific and positive material demonstrating fraud, collusion, wilful misstatement or suppression of facts; mere non payment or bona fide belief in non taxability is insufficient. On the facts, disclosure in the taxpayer's registration and absence of specific allegations meant the proviso could not sustain the extended period demand, so the extended period demand was quashed while taxability was affirmed. Case-Laws Service Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786873