https://www.taxtmi.com/caselaws?id=787129 Invocation of the extended limitation proviso to Section 73(1) of the Finance Act, 1994 was examined against requirements that non payment be attributable to fraud, collusion, wilful misstatement, suppression of facts or contravention with intent to evade tax. The record shows filed ST 3 returns and ITRs and a bona fide position on taxability; adjudication relied on third party reconciliation without specific positive material or show cause notice averments of mala fide conduct. Consequently the extended period could not be invoked and the departmental demand founded on that extended limitation was set aside, allowing the appeal for the assessee. en-us Wed, 25 Feb 2026 00:00:00 +0530 Fri, 27 Feb 2026 08:36:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787129 Invocation of the extended limitation proviso to Section 73(1) of the Finance Act, 1994 was examined against requirements that non payment be attributable to fraud, collusion, wilful misstatement, suppression of facts or contravention with intent to evade tax. The record shows filed ST 3 returns and ITRs and a bona fide position on taxability; adjudication relied on third party reconciliation without specific positive material or show cause notice averments of mala fide conduct. Consequently the extended period could not be invoked and the departmental demand founded on that extended limitation was set aside, allowing the appeal for the assessee. Case-Laws Service Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787129