Extended Limitation under Section 73(1) Cannot Be Invoked Without Mens Rea: CESTAT Delhi

Globe Ground India Private Ltd. Vs Commissioner of CGST (CESTAT Delhi) The Delhi Bench of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT) in Globe Ground India Pvt. Ltd. vs Commissioner of CGST (order dated 14 October 2025) allowed the assessee’s appeal by holding that the extended limitation period under the proviso to Section 73(1) of the Finance Act, 1994, could not be invoked in the absence of any evidence of wilful suppression or intent to evade service tax. The case concerned a dispute for the financial years 2014–15 to the first quarter of 2017–18. The department h...