https://www.taxtmi.com/caselaws?id=800368 Service-tax demands for the pre-1 July 2012 positive-list regime require the show-cause notice to identify the applicable taxable-service category and statutory basis; aggregated receipt differences without classification do not provide a valid foundation for demand. For the negative-list period, liability must rest on the applicable charging provision, including Section 66B, rather than superseded positive-list provisions. Differences between ST-3 returns, audited financial statements and Form 26AS data alone do not establish wilful suppression or intent to evade tax. Without supporting verification or evidence of such intent, extended limitation, consequential interest and penalties cannot be sustained. en-us Fri, 25 Sep 2026 00:00:00 +0530 Tue, 06 Oct 2026 08:13:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=800368 Service-tax demands for the pre-1 July 2012 positive-list regime require the show-cause notice to identify the applicable taxable-service category and statutory basis; aggregated receipt differences without classification do not provide a valid foundation for demand. For the negative-list period, liability must rest on the applicable charging provision, including Section 66B, rather than superseded positive-list provisions. Differences between ST-3 returns, audited financial statements and Form 26AS data alone do not establish wilful suppression or intent to evade tax. Without supporting verification or evidence of such intent, extended limitation, consequential interest and penalties cannot be sustained. Case-Laws Service Tax Fri, 25 Sep 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=800368