Extended Period of Limitation: Demand held time barred where taxpayer filed ST 3 returns and acted on bona fide self assessment.

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....The article addresses invocation of the extended period of limitation for service tax demands where the taxpayer filed ST 3 returns and ITRs and performed self-assessment. It emphasises that show cause notices must specify the allegations and that extended limitation cannot be invoked where the appellant demonstrated bona fide belief in classifying services as exempt and consistently filed returns; the demand based on differences between ITR/Form 26AS and ST 3 without specifying service nature was held time barred and unsustainable.....