https://www.taxtmi.com/caselaws?id=786863 Invocation of the proviso to Section 73(1) for extending the limitation period requires positive, deliberate evidence of fraud, collusion, wilful misstatement or suppression of facts with intent to evade tax; mere receipt of third party information or absence of documentary explanation is insufficient. The initial burden rests on the department to produce material establishing deliberate suppression, after which the burden may shift. Applying these principles, the extended period could not be validly invoked in the absence of such positive evidence, and the demand for service tax, interest and penalties under the extended period was held time barred and set aside. en-us Mon, 19 Jan 2026 00:00:00 +0530 Sat, 21 Feb 2026 09:29:47 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=786863 Invocation of the proviso to Section 73(1) for extending the limitation period requires positive, deliberate evidence of fraud, collusion, wilful misstatement or suppression of facts with intent to evade tax; mere receipt of third party information or absence of documentary explanation is insufficient. The initial burden rests on the department to produce material establishing deliberate suppression, after which the burden may shift. Applying these principles, the extended period could not be validly invoked in the absence of such positive evidence, and the demand for service tax, interest and penalties under the extended period was held time barred and set aside. Case-Laws Service Tax Mon, 19 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=786863