https://www.taxtmi.com/caselaws?id=796459 Service-tax demands based solely on differences between Form 26AS and ST-3 returns cannot invoke the extended limitation period without affirmative evidence of fraud, wilful suppression or intent to evade tax; the demand, related interest and penalty for tax evasion were therefore time-barred. Mandatory pre-show cause notice consultation, required for the applicable demand category when the notice was issued, was not undertaken and independently vitiated the notice; a later circular could not retrospectively cure that defect. However, admitted delayed filing of ST-3 returns remained an independent procedural default, and the separate penalty for delayed filing was upheld. en-us Wed, 05 Aug 2026 00:00:00 +0530 Thu, 06 Aug 2026 09:11:12 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=796459 Service-tax demands based solely on differences between Form 26AS and ST-3 returns cannot invoke the extended limitation period without affirmative evidence of fraud, wilful suppression or intent to evade tax; the demand, related interest and penalty for tax evasion were therefore time-barred. Mandatory pre-show cause notice consultation, required for the applicable demand category when the notice was issued, was not undertaken and independently vitiated the notice; a later circular could not retrospectively cure that defect. However, admitted delayed filing of ST-3 returns remained an independent procedural default, and the separate penalty for delayed filing was upheld. Case-Laws Service Tax Wed, 05 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=796459