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    <title>2023 (9) TMI 656 - CESTAT AHMEDABAD</title>
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    <description>ERP implementation service received from a foreign parent was treated as Information Technology Service for a period preceding the specific taxable entry introduced on 16.05.2008, so it could not be forced into Business Auxiliary Service for that earlier period. The analysis notes that the Revenue itself accepted the service under the later entry for the subsequent period, supporting exclusion from BAS in the disputed period. It also states that the demand was unsustainable on limitation and revenue-neutrality grounds because any tax would have been available as Cenvat credit, negating suppression or wilful intent and defeating extended limitation and penalties.</description>
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      <description>ERP implementation service received from a foreign parent was treated as Information Technology Service for a period preceding the specific taxable entry introduced on 16.05.2008, so it could not be forced into Business Auxiliary Service for that earlier period. The analysis notes that the Revenue itself accepted the service under the later entry for the subsequent period, supporting exclusion from BAS in the disputed period. It also states that the demand was unsustainable on limitation and revenue-neutrality grounds because any tax would have been available as Cenvat credit, negating suppression or wilful intent and defeating extended limitation and penalties.</description>
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