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    <description>A transaction involving Certificate of Authenticity stickers and labels for thin client devices with embedded Microsoft software was treated as a sale of an embedded product, not a taxable Information Technology Software Service, because the record showed no transfer of copyright or commercial software rights; no service tax was payable under reverse charge. The demand was also held time-barred because the labels were imported under Bills of Entry and were known to the Department, so suppression of facts or wilful misstatement was not established and the extended limitation period could not be invoked. The tax demand, interest and penalties did not survive.</description>
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