https://www.taxtmi.com/caselaws?id=787396 Invocation of the proviso to Section 73(1) to extend the limitation period was rejected because there were no specific allegations or evidence of fraud, collusion, wilful misstatement or deliberate suppression of facts; the appellant possessed a bona fide belief that Notification No.30/2012-ST shifted service tax liability to the service recipient for rent-a-cab services, and absence of ST-3 filings or non-payment alone does not satisfy the positive-evidence requirement to trigger extended limitation. Consequently, the extended-period demand, interest and penalties were held time-barred and set aside in favour of the assessee. en-us Mon, 19 Jan 2026 00:00:00 +0530 Tue, 03 Mar 2026 12:35:36 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=787396 Invocation of the proviso to Section 73(1) to extend the limitation period was rejected because there were no specific allegations or evidence of fraud, collusion, wilful misstatement or deliberate suppression of facts; the appellant possessed a bona fide belief that Notification No.30/2012-ST shifted service tax liability to the service recipient for rent-a-cab services, and absence of ST-3 filings or non-payment alone does not satisfy the positive-evidence requirement to trigger extended limitation. Consequently, the extended-period demand, interest and penalties were held time-barred and set aside in favour of the assessee. Case-Laws Service Tax Mon, 19 Jan 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=787396