The Court held that mere issuance of a DRC-01 summary without an accompanying detailed SCN is insufficient to initiate proceedings under Section 73.

CESTAT held that service tax is not payable on the use of foreign technology or trademarks not registered under Indian law, setting aside the demand

The Bench rejected the Revenue’s reliance on Section 153(6), observing that no finding or direction had been issued by any court to extend the limitation period. The Court further clarified that the AO was required to complete the reassessment within 60 days of the interim stay being vacated in December 2023, which had lapsed by February 2024