https://www.taxtmi.com/caselaws?id=788157 Extended limitation cannot be invoked where identical facts were already known to the Department and an earlier SCN on the same facts existed; therefore the later SCN for the relevant year was held unsustainable. Demands founded solely on third party income tax data without examination of the assessee's books and records are not maintainable; mechanical reliance on Form 26AS entries was rejected. Transactions evidenced as pure trading in goods, with tax discharged under VAT, fall within the negative list exemption and do not attract service tax. Appeal allowed; impugned order set aside on limitation and merits. en-us Fri, 13 Mar 2026 00:00:00 +0530 Wed, 18 Mar 2026 08:20:54 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=788157 Extended limitation cannot be invoked where identical facts were already known to the Department and an earlier SCN on the same facts existed; therefore the later SCN for the relevant year was held unsustainable. Demands founded solely on third party income tax data without examination of the assessee's books and records are not maintainable; mechanical reliance on Form 26AS entries was rejected. Transactions evidenced as pure trading in goods, with tax discharged under VAT, fall within the negative list exemption and do not attract service tax. Appeal allowed; impugned order set aside on limitation and merits. Case-Laws Service Tax Fri, 13 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=788157