Time-share accommodation arrangements fall outside Club or...

Time-share accommodation arrangements fall outside Club or Association Service where purchasers receive only contractual occupancy rights for specified periods, without ownership, voting, management or other club-membership rights. Contractual use of the term "member" does not determine classification; consideration linked to accommodation categories, absence of conventional subscriptions and resort access for ordinary guests support treatment as accommodation services. A later distinct taxable entry for short-term accommodation further supports that conclusion. Pre-notice payment of tax and applicable interest, absent fraud, collusion or wilful suppression, attracts statutory protection and precludes penalty-only proceedings. Suppression penalties also require evidence of deliberate evasion, not merely a bona fide classification dispute disclosed in regular audited accounts.