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    <title>2026 (7) TMI 458 - CESTAT KOLKATA</title>
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    <description>Service tax demand based mainly on Form 26AS data was found unsustainable because it lacked independent verification and corroborative material establishing taxable service liability. The record showed that a substantial part of the demand had already been dropped on documentary evidence, which reinforced the finding that the notice was issued without proper investigation. In the absence of material showing suppression or any other ground justifying the extended limitation period, the demand was held time-barred and the extended period under section 73 of the Finance Act, 1994 was not invokable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794572</link>
      <description>Service tax demand based mainly on Form 26AS data was found unsustainable because it lacked independent verification and corroborative material establishing taxable service liability. The record showed that a substantial part of the demand had already been dropped on documentary evidence, which reinforced the finding that the notice was issued without proper investigation. In the absence of material showing suppression or any other ground justifying the extended limitation period, the demand was held time-barred and the extended period under section 73 of the Finance Act, 1994 was not invokable.</description>
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