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    <title>2023 (3) TMI 379 - CESTAT NEW DELHI</title>
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    <description>Wireline logging, perforation and data processing services were accepted by the department as mining services from 1.6.2007, and could not be reclassified as technical testing and analysis services without showing why the accepted classification was wrong. On that basis, the demand on classification failed on merits. Extended limitation under section 73 could not be invoked merely because of incorrect self-assessment; the statutory elements of fraud, collusion, wilful misstatement, suppression of facts, or intent to evade tax were absent. As the demand itself was unsustainable, the interest and penalties also could not survive, and the appeal succeeded with consequential relief.</description>
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