https://www.taxtmi.com/caselaws?id=790207 Service tax liability cannot be established solely from discrepancies between income tax returns, Form 26AS and ST-3 returns; the taxable value must be verified by reference to the actual service, recipient, consideration and any relevant exclusions, exemptions or reverse charge treatment. On that basis, a demand based only on return mismatch was not sustainable. The extended period of limitation also requires positive material showing suppression, wilful misstatement, fraud or deliberate intent to evade tax; mere non-reconciliation of figures or reliance on third-party data is insufficient. In the absence of such ingredients, the extended period was not invocable, and the demand, interest and penalties were set aside. en-us Tue, 21 Apr 2026 00:00:00 +0530 Wed, 22 Apr 2026 10:36:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=790207 Service tax liability cannot be established solely from discrepancies between income tax returns, Form 26AS and ST-3 returns; the taxable value must be verified by reference to the actual service, recipient, consideration and any relevant exclusions, exemptions or reverse charge treatment. On that basis, a demand based only on return mismatch was not sustainable. The extended period of limitation also requires positive material showing suppression, wilful misstatement, fraud or deliberate intent to evade tax; mere non-reconciliation of figures or reliance on third-party data is insufficient. In the absence of such ingredients, the extended period was not invocable, and the demand, interest and penalties were set aside. Case-Laws Service Tax Tue, 21 Apr 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=790207