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    <title>2022 (8) TMI 407 - ALLAHABAD HIGH COURT</title>
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    <description>The Tribunal&#039;s finding that there was no wilful suppression of facts defeated invocation of the extended period of limitation, and that factual conclusion was accepted on review. The Tribunal also held, after analysing the service tax law and earlier decisions, that the respondent-assessee&#039;s work was exempt. Because the challenge depended on those factual findings and on settled legal principles, the Court held that no substantial question of law arose for interference under section 35G. The revenue appeal therefore failed and the Tribunal&#039;s conclusions were left undisturbed.</description>
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      <description>The Tribunal&#039;s finding that there was no wilful suppression of facts defeated invocation of the extended period of limitation, and that factual conclusion was accepted on review. The Tribunal also held, after analysing the service tax law and earlier decisions, that the respondent-assessee&#039;s work was exempt. Because the challenge depended on those factual findings and on settled legal principles, the Court held that no substantial question of law arose for interference under section 35G. The revenue appeal therefore failed and the Tribunal&#039;s conclusions were left undisturbed.</description>
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