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    <description>For the interim period governing goods transport operator service, the recipient was treated as liable only under the later deeming scheme, while the return-filing obligation arose under section 71A rather than section 70 of the Finance Act, 1994. Following earlier decisions and the later Supreme Court ruling on the same point, proceedings under section 73(1)(a) for alleged non-filing of return could not be sustained against a person not bound by section 70 for that period. As the tax had already been paid, interest and penalty were held unsustainable and were set aside.</description>
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