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of The HC determined that BRPNNL, a public limited company, does not qualify as a governmental authority and cannot claim exemption from service tax. The court held that the 'centage' received by the petitioner constitutes taxable services under the Finance Act, 1994. The extended period of limitation was justified due to willful suppression of facts and intent to evade service tax. The court directed the petitioner to pursue statutory remedies through an appeal under Section 86 of the Finance Act, 1994, with potential consideration of limitation periods spent in the writ application.
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