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of The case involves a dispute u/s classification of services for tax purposes. The appellant provided services as a sub-contractor for printing voter rolls and cards. The services were classified as Business Auxiliary Services due to commission-based arrangement with UPDESCO. The liability to pay service tax as a sub-contractor was upheld, following precedent. The extended period of limitation for penalty was questioned, with the need for verification of tax payments post 01.07.2010. The imposition of penalty u/s 76 for the period prior to 09.05.2008 was deemed unjustified due to limitation. The appeal was partially allowed, remanding for re-computation of tax liability for the normal period.
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