Development-agreement land transfers held transfers of ownership not taxable; s.73(1) extended limitation inapplicable for mere disclosure

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....Development-agreement receipts were analysed for service tax liability and applicability of extended limitation. Extended limitation requires wilful concealment with intent to evade tax; mere disclosure in published accounts and unelaborated allegations cannot sustain invocation of extended limitation, so the extended period was held inapplicable. Transfers of undivided land interest to developers in consideration of payment were characterised as transfers of ownership rather than taxable services, removing service tax liability on those receipts. Miscellaneous receipts treated under professional fee heads do not automatically attract service tax and, where they fall below the annual threshold, give rise to no liability.....