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of CESTAT partly allows the appeal. The Appellant's nature of activities providing wildlife/eco-adventure tour packages is held not to constitute 'tour operator' services and is excluded from service tax liability; receipts characterized as hotel/resort accommodation are held outside the ambit of 'renting of immovable property' services. Conversely, services rendered under the agreement with the government for short-duration training are held to fall within 'commercial training and coaching services,' confirming taxability on that head. The order invoking the extended period of limitation and the penalties imposed are set aside; consequential relief, if any, is to follow in accordance with law. Appeal allowed in part.
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