https://www.taxtmi.com/caselaws?id=799353 Extended limitation for service-tax demands relating to manpower supplied by an overseas holding company requires wilful suppression of facts or deliberate misstatement. A bona fide and legally tenable view on taxability does not establish those conditions. Where the arrangement is treated as receipt of manpower recruitment or supply service but no mala fide conduct is shown, service-tax demand remains sustainable only within the normal limitation period, with applicable interest. The extended-period demand and associated penalties cannot be sustained. en-us Mon, 30 Mar 2026 00:00:00 +0530 Mon, 21 Sep 2026 08:57:08 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=799353 Extended limitation for service-tax demands relating to manpower supplied by an overseas holding company requires wilful suppression of facts or deliberate misstatement. A bona fide and legally tenable view on taxability does not establish those conditions. Where the arrangement is treated as receipt of manpower recruitment or supply service but no mala fide conduct is shown, service-tax demand remains sustainable only within the normal limitation period, with applicable interest. The extended-period demand and associated penalties cannot be sustained. Case-Laws Service Tax Mon, 30 Mar 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=799353