Extended Limitation for Service Tax Requires Proof of Wilful Suppression to Evade Tax, Mere Suppression Insufficient.

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....Extended period of limitation - It is clear that even when an assessee has suppressed facts, the extended period of limitation can be invoked only when “suppression’ is shown to be wilful with intent to evade the payment of service tax - even suppression of facts has to be wilful and in any case, suppression has also to be with an intent to evade the payment of service tax. - AT....