https://www.taxtmi.com/caselaws?id=795895 A sub-contractor has an independent obligation to pay service tax on consideration received, and payment by the principal contractor does not extinguish that liability. However, the extended limitation period under the proviso to Section 73(1) of the Finance Act, 1994 cannot apply without substantive evidence of wilful suppression of facts with intent to evade tax. Where conflicting Tribunal decisions made sub-contractor liability an interpretational issue until settled by a Larger Bench, extended limitation is not justified. Accordingly, although the underlying service tax liability was affirmed, the demand was barred by limitation. en-us Mon, 27 Jul 2026 00:00:00 +0530 Wed, 29 Jul 2026 08:21:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=795895 A sub-contractor has an independent obligation to pay service tax on consideration received, and payment by the principal contractor does not extinguish that liability. However, the extended limitation period under the proviso to Section 73(1) of the Finance Act, 1994 cannot apply without substantive evidence of wilful suppression of facts with intent to evade tax. Where conflicting Tribunal decisions made sub-contractor liability an interpretational issue until settled by a Larger Bench, extended limitation is not justified. Accordingly, although the underlying service tax liability was affirmed, the demand was barred by limitation. Case-Laws Service Tax Mon, 27 Jul 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=795895