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    <title>2026 (7) TMI 156 - CESTAT KOLKATA</title>
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    <description>Service tax liability cannot be sustained merely from Form 26AS or similar income-tax data unless supported by independent corroborative evidence showing the taxable service and the correct person liable to tax. In the stated analysis, invoices explained the receipts as manpower services, for which liability lay on the recipient under reverse charge, and the demand based only on third-party tax data was rejected. The discussion also notes that limitation must be independently established; a notice founded only on such data may fail on time-bar grounds as well. The pre-deposit defect was treated as cured where the challans collectively covered the required amount.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794270</link>
      <description>Service tax liability cannot be sustained merely from Form 26AS or similar income-tax data unless supported by independent corroborative evidence showing the taxable service and the correct person liable to tax. In the stated analysis, invoices explained the receipts as manpower services, for which liability lay on the recipient under reverse charge, and the demand based only on third-party tax data was rejected. The discussion also notes that limitation must be independently established; a notice founded only on such data may fail on time-bar grounds as well. The pre-deposit defect was treated as cured where the challans collectively covered the required amount.</description>
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