Service Tax Escapement in Audit Doesn't Imply Fraud; Extended Limitation Period Unjustified Without Intent to Evade Tax.

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....Extended period of limitation - If the audit detected escapement of service tax, it does not establish, in the factual matrix of this case, that the assessee has indulged in fraud or collusion or wilful mis-statement or suppression of facts or violation of legal praising with an intent to evade payment of service tax. It only establishes that the officer tasked with the best judgment assessment has not done his job. This cannot be the ground on which extended period of limitation can be invoked. - AT....