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    <description>Prior disclosure of user development fee receipts to the department defeated invocation of the extended limitation period, because there was no suppression of facts or intent to evade duty. The fee was also not taxable as port service, since no specific service to vessels or goods was established and the receipts were treated as a statutory levy under the Gujarat Maritime Board Act, 1981 rather than consideration for service. On that basis, the demand was unsustainable both on limitation and on merits.</description>
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      <description>Prior disclosure of user development fee receipts to the department defeated invocation of the extended limitation period, because there was no suppression of facts or intent to evade duty. The fee was also not taxable as port service, since no specific service to vessels or goods was established and the receipts were treated as a statutory levy under the Gujarat Maritime Board Act, 1981 rather than consideration for service. On that basis, the demand was unsustainable both on limitation and on merits.</description>
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