Transfer of possession and effective control of deep freezers,...

Transfer of possession and effective control of deep freezers, giving dealers an exclusive right to use them during the agreements, constitutes a deemed sale excluded from service tax. Supply without transfer of that right is a declared service. Interest-free security deposits refundable when the freezers are returned, subject to deductions for damage, are not consideration for a service; taxable consideration must have a nexus with the service. Extended limitation requires a positive act of suppression with intent to evade tax, with the burden on the Revenue. Non-registration and non-filing for a non-taxable activity, or existing reverse-charge registration, do not establish deliberate suppression.