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    <title>2023 (1) TMI 188 - CESTAT AHMEDABAD</title>
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    <description>The Tribunal determined that &quot;Software Activation&quot; charges constituted a sale of goods, not a taxable service. Consequently, the applicability of Service Tax was negated, as the appellant was deemed a seller of goods rather than a service provider. The Tribunal found the Revenue&#039;s Service Tax demand to be incorrectly calculated and beyond the scope of the Show Cause Notice, thereby violating principles of natural justice. The Tribunal also ruled that the extended limitation period for Service Tax demand was inapplicable. The appeal was allowed, and the impugned order was set aside, granting consequential relief to the appellant.</description>
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      <title>2023 (1) TMI 188 - CESTAT AHMEDABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=432441</link>
      <description>The Tribunal determined that &quot;Software Activation&quot; charges constituted a sale of goods, not a taxable service. Consequently, the applicability of Service Tax was negated, as the appellant was deemed a seller of goods rather than a service provider. The Tribunal found the Revenue&#039;s Service Tax demand to be incorrectly calculated and beyond the scope of the Show Cause Notice, thereby violating principles of natural justice. The Tribunal also ruled that the extended limitation period for Service Tax demand was inapplicable. The appeal was allowed, and the impugned order was set aside, granting consequential relief to the appellant.</description>
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