https://www.taxtmi.com/caselaws?id=786871 The tribunal addressed whether the extended limitation period under the proviso could be invoked and whether attendant interest and penalties were sustainable. It applied the legal principle that invocation of the extended period requires specific averments that tax was unpaid by reason of fraud, collusion, wilful misstatement or suppression with intent to evade, and noted statutory protection where tax and interest have been paid and information furnished before a notice. Finding the show cause notice lacked the mandatory specific averments, the appellant had paid tax and interest pre-notice, and revenue failed to rebut explanations, the extended-period demand and related interest and penalties were set aside. en-us Fri, 20 Feb 2026 00:00:00 +0530 Sat, 21 Feb 2026 09:29:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786871 The tribunal addressed whether the extended limitation period under the proviso could be invoked and whether attendant interest and penalties were sustainable. It applied the legal principle that invocation of the extended period requires specific averments that tax was unpaid by reason of fraud, collusion, wilful misstatement or suppression with intent to evade, and noted statutory protection where tax and interest have been paid and information furnished before a notice. Finding the show cause notice lacked the mandatory specific averments, the appellant had paid tax and interest pre-notice, and revenue failed to rebut explanations, the extended-period demand and related interest and penalties were set aside. Case-Laws Service Tax Fri, 20 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786871