Exemption for examination-related services rejected where recipients were commercial entities; suppression sustained extended limitation and penalties...
Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.
Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.
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