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    <title>2015 (5) TMI 143 - CESTAT MUMBAI</title>
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    <description>Deposit insurance activity was treated as miscellaneous insurance business falling within the taxable service for general insurance business under the Finance Act, 1994, with tax payable only from 20/09/2011 onwards. The activity was characterised as organised commercial business for consideration by way of premium, not a sovereign function immune from service tax. It was also held to be a contract of insurance and indemnity, rather than a mere contract of guarantee. Exemption under Notification No. 22/2006-ST was denied because it applied only to services provided by RBI, and the appellant was a separate legal entity. Extended limitation and penalties were not sustained because the dispute involved classification and interpretive issues, resulting in waiver of penalty and partial relief.</description>
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