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    <description>Extended limitation for service tax demand was unavailable because the record did not show fraud, wilful misstatement, suppression of facts, or intent to evade tax; the transactions were reflected in the books and the assessee had a bona fide belief on taxability. The time-barred portion of the demand was therefore not sustainable, while the demand for the normal limitation period remained intact. For the same reason, the penalties were held unsustainable, as the ingredients for penal action were absent in a bona fide dispute.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794124</link>
      <description>Extended limitation for service tax demand was unavailable because the record did not show fraud, wilful misstatement, suppression of facts, or intent to evade tax; the transactions were reflected in the books and the assessee had a bona fide belief on taxability. The time-barred portion of the demand was therefore not sustainable, while the demand for the normal limitation period remained intact. For the same reason, the penalties were held unsustainable, as the ingredients for penal action were absent in a bona fide dispute.</description>
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