Case of Stemcyte India Therapeutical Pvt Ltd vs Commissioner of Central excise and Service Tax, SC Judgement Dated 14th July 2025. The apex court held that the activity of enrolment, collection, processing, and storage of umbilical cord blood stem cells fell within the scope of exempted “Healthcare Services” and therefore, was not liable to service tax. in the absence of fraud, collusion, wilful misstatement, or suppression of facts with an intent to evade payment of service tax, the invocation of the extended period of limitation, is wholly unwarranted. Mere non-payment of service tax, by itself, does not justify the invocation of the extended limitation period.