https://www.taxtmi.com/caselaws?id=795112 Extended limitation for service-tax recovery requires fraud, collusion, wilful misstatement, suppression, or contravention with intent to evade; uncertainty over the taxability of wheeling charges and cross-subsidy surcharges made the dispute interpretative and did not establish those prerequisites. Recovery beyond the normal limitation period was therefore unsustainable. Wheeling charges for use of a distribution network and cross-subsidy surcharges under the electricity-law framework were intrinsically connected with electricity transmission or distribution. As neither charge was consideration for agreeing to tolerate an act, neither constituted a declared service, and no service-tax liability arose. en-us Wed, 15 Jul 2026 00:00:00 +0530 Fri, 17 Jul 2026 08:37:31 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795112 Extended limitation for service-tax recovery requires fraud, collusion, wilful misstatement, suppression, or contravention with intent to evade; uncertainty over the taxability of wheeling charges and cross-subsidy surcharges made the dispute interpretative and did not establish those prerequisites. Recovery beyond the normal limitation period was therefore unsustainable. Wheeling charges for use of a distribution network and cross-subsidy surcharges under the electricity-law framework were intrinsically connected with electricity transmission or distribution. As neither charge was consideration for agreeing to tolerate an act, neither constituted a declared service, and no service-tax liability arose. Case-Laws Service Tax Wed, 15 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795112