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Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word "culture" was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.
Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word "culture" was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.
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