https://www.taxtmi.com/caselaws?id=789302 Extended limitation under the proviso to Section 73(1) of the Finance Act, 1994 could not be invoked without evidence of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax. Mere non-payment or short payment was insufficient, and the assessee had disclosed relevant returns, income-tax records, bank statements, and reconciliation worksheets during inquiry. The absence of deliberate concealment, the demand being enhanced on the assessee's own quantification, and available unutilised Cenvat credit exceeding the tax liability all negatived intent to evade. The demand was therefore barred by limitation. en-us Wed, 25 Feb 2026 00:00:00 +0530 Tue, 07 Apr 2026 07:48:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=789302 Extended limitation under the proviso to Section 73(1) of the Finance Act, 1994 could not be invoked without evidence of fraud, collusion, wilful misstatement, suppression of facts, or contravention with intent to evade tax. Mere non-payment or short payment was insufficient, and the assessee had disclosed relevant returns, income-tax records, bank statements, and reconciliation worksheets during inquiry. The absence of deliberate concealment, the demand being enhanced on the assessee's own quantification, and available unutilised Cenvat credit exceeding the tax liability all negatived intent to evade. The demand was therefore barred by limitation. Case-Laws Service Tax Wed, 25 Feb 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=789302