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of The SC held that services related to enrolment, collection, processing, and storage of umbilical cord blood stem cells constitute 'Healthcare Services' and qualify for exemption from service tax during the disputed period. The extended limitation period under Section 73 of the Finance Act, 1994 cannot be invoked absent any fraud, collusion, wilful misstatement, or suppression of facts with intent to evade tax; mere non-payment is insufficient. The show cause notice was found time-barred, and penalties imposed were unjustified as the appellant did not conceal material facts and sought clarifications from the Department. The notification clarifying the healthcare exemption is prospective and clarificatory, benefiting the appellant. Consequently, the impugned order was set aside in its entirety, and the appeals were allowed.
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