https://www.taxtmi.com/caselaws?id=467816 A writ court should ordinarily not interfere with a show cause notice where the plea of limitation depends on a disputed allegation of evasion of service tax. An allegation of evasion can attract the extended limitation under the proviso to Section 73(1) of the Finance Act, 1994, but whether such evasion is made out is a factual question. Because that factual dispute also goes to the merits of the proceedings, it is not normally examined under Article 226. The petitioner was directed to raise all objections, including limitation and jurisdiction, before the issuing authority for decision in accordance with law. en-us Tue, 23 Aug 2022 00:00:00 +0530 Sat, 04 Apr 2026 12:02:39 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=467816 A writ court should ordinarily not interfere with a show cause notice where the plea of limitation depends on a disputed allegation of evasion of service tax. An allegation of evasion can attract the extended limitation under the proviso to Section 73(1) of the Finance Act, 1994, but whether such evasion is made out is a factual question. Because that factual dispute also goes to the merits of the proceedings, it is not normally examined under Article 226. The petitioner was directed to raise all objections, including limitation and jurisdiction, before the issuing authority for decision in accordance with law. Case-Laws Indian Laws Tue, 23 Aug 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=467816