In what circumstances extended period of limitation is not enforceable? Whether SCN can be issued for period beyond 18 months even if assessee has bona fide belief regarding service tax liability?

Extended limitation period: not available where assessee had bona fide belief or doubt about service tax liability.

Extended limitation cannot be invoked where the assessee had a bona fide belief that no service tax was payable, where bona fide doubt existed about chargeability, where the assessee voluntarily approached the department earlier, where the issue is one of legal interpretation creating genuine confusion, or where earlier favorable decisions were subsequently overruled without evidence of suppression.