Third Party Data cannot be a cause for extended Limitation

A service tax demand for 2014-15 was raised only in 2020, based on Income Tax Department data. 

CESTAT Chandigarh held that the Revenue had produced no evidence of suppression, fraud or intent to evade tax. 

A bona fide belief regarding exemption further supported the assessee. Following Uniworth Textiles, the Tribunal held that mere non-payment is not enough to invoke extended limitation and set aside the entire demand.