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    <description>A contract must be read as a whole, and its substance prevails over its title for determining Cenvat credit eligibility. Although the agreement was styled as a maintenance contract, it required marketing, promotion, advertising, public relations and event-related activities, so the services fell within input services under the Cenvat Credit Rules, 2004 and credit was admissible. The extended limitation period could not be invoked without ation of suppression or misstatement with intent to evade duty; in the absence of such evidence, the show cause notice was time-barred and penalty was not leviable.</description>
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