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    <description>Persistent non-cooperation in adjudicatory proceedings may justify best judgment assessment where the assessee does not reply to notices, furnish details, or appear for hearings, and the Tribunal treated such conduct as supporting an adverse inference. On the service tax issue, inspection, sorting and rework were treated as prima facie falling within Business Auxiliary Service, with import of those services attracting reverse charge liability. For stay of recovery, the Tribunal found the challenge to the quantum partly arguable but required a conditional pre-deposit because the record suggested suppression and the statutory pre-deposit requirement was attracted; recovery of the balance was stayed on compliance.</description>
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      <description>Persistent non-cooperation in adjudicatory proceedings may justify best judgment assessment where the assessee does not reply to notices, furnish details, or appear for hearings, and the Tribunal treated such conduct as supporting an adverse inference. On the service tax issue, inspection, sorting and rework were treated as prima facie falling within Business Auxiliary Service, with import of those services attracting reverse charge liability. For stay of recovery, the Tribunal found the challenge to the quantum partly arguable but required a conditional pre-deposit because the record suggested suppression and the statutory pre-deposit requirement was attracted; recovery of the balance was stayed on compliance.</description>
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