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    <description>Valuation of goods in contracts for erection, commissioning and installation required segregating supply and service components; where contracts, invoices and books separately disclose goods value and VAT/CST was paid on supply, that supply constitutes sale and is excluded from taxable value of service, resulting in no service tax demand on goods. Allegations of suppression, fraud or misstatement were rejected because the appellant had bona fide belief based on contractual allocations and main contractor practices; consequently extended period of limitation was not attracted and the appeal was allowed in favour of the appellant.</description>
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