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Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties.
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Exemption for services relating to conduct of examination was denied because the agreements showed the work was rendered to commercial entities, not to an educational institution. Services for a computer-based training module and assessment activities had no nexus with admission to, or conduct of examination by, an educational institution, and one agreement expressly contemplated payment of service tax, undermining the claim of bona fide exemption. The extended period of limitation was upheld because the appellant failed to disclose records and did not produce agreements despite summons, amounting to suppression of facts. Penalties and interest were also sustained as consequential liabilities.
Exemption for services relating to conduct of examination was denied because the agreements showed the work was rendered to commercial entities, not to an educational institution. Services for a computer-based training module and assessment activities had no nexus with admission to, or conduct of examination by, an educational institution, and one agreement expressly contemplated payment of service tax, undermining the claim of bona fide exemption. The extended period of limitation was upheld because the appellant failed to disclose records and did not produce agreements despite summons, amounting to suppression of facts. Penalties and interest were also sustained as consequential liabilities.
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