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    <title>2026 (3) TMI 1316 - CESTAT CHENNAI</title>
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    <description>Under Section 73(1) of the Finance Act, 1994, the normal limitation period applied, and the extended period could be used only on proof of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax. On the record, the assessee was registered, filed ST-3 returns, and had been subject to audit and departmental correspondence, so deliberate suppression with intent to evade service tax was not established. The extended period was therefore not invocable, and the demand was barred by limitation. As limitation was ative, the merits of the credit and exemption dispute were left unexamined as inconsequential.</description>
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      <title>2026 (3) TMI 1316 - CESTAT CHENNAI</title>
      <link>https://www.taxtmi.com/caselaws?id=788561</link>
      <description>Under Section 73(1) of the Finance Act, 1994, the normal limitation period applied, and the extended period could be used only on proof of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax. On the record, the assessee was registered, filed ST-3 returns, and had been subject to audit and departmental correspondence, so deliberate suppression with intent to evade service tax was not established. The extended period was therefore not invocable, and the demand was barred by limitation. As limitation was ative, the merits of the credit and exemption dispute were left unexamined as inconsequential.</description>
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