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    <title>2026 (6) TMI 1424 - CESTAT NEW DELHI</title>
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    <description>A service tax demand on legal services received under reverse charge was found time-barred for the period beyond five years, and the show cause notice was issued too late for October 2014 to September 2015. For the balance period, extended limitation under Section 73 of the Finance Act, 1994 required proof of fraud, collusion, wilful misstatement, or deliberate suppression with intent to evade tax. On the record, no such intent was shown, as the assessee had been regularly paying output service tax in cash and no positive act of evasion was established. The demand was therefore set aside on limitation.</description>
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      <title>2026 (6) TMI 1424 - CESTAT NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=794043</link>
      <description>A service tax demand on legal services received under reverse charge was found time-barred for the period beyond five years, and the show cause notice was issued too late for October 2014 to September 2015. For the balance period, extended limitation under Section 73 of the Finance Act, 1994 required proof of fraud, collusion, wilful misstatement, or deliberate suppression with intent to evade tax. On the record, no such intent was shown, as the assessee had been regularly paying output service tax in cash and no positive act of evasion was established. The demand was therefore set aside on limitation.</description>
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