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    <title>2026 (6) TMI 10 - CESTAT ALLAHABAD</title>
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    <description>A later service tax demand based on the same material and substantially identical allegations as an earlier show cause notice could not justify invocation of the extended period of limitation. Because the relevant facts were already within the department&#039;s knowledge, the allegation of suppression for the later period was unsustainable. The tribunal applied the settled principle that a subsequent demand on the same set of facts does not permit reopening through the extended limitation period merely for a different tax period. The demand was therefore time-barred, and the consequential demand, interest and penalties could not survive.</description>
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    <pubDate>Fri, 29 May 2026 00:00:00 +0530</pubDate>
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      <title>2026 (6) TMI 10 - CESTAT ALLAHABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=792629</link>
      <description>A later service tax demand based on the same material and substantially identical allegations as an earlier show cause notice could not justify invocation of the extended period of limitation. Because the relevant facts were already within the department&#039;s knowledge, the allegation of suppression for the later period was unsustainable. The tribunal applied the settled principle that a subsequent demand on the same set of facts does not permit reopening through the extended limitation period merely for a different tax period. The demand was therefore time-barred, and the consequential demand, interest and penalties could not survive.</description>
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      <pubDate>Fri, 29 May 2026 00:00:00 +0530</pubDate>
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