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    <description>A university&#039;s distance-education arrangement remained within the educational services negative list and exemption framework because it retained control over curriculum, admissions, examinations, results and degree awards, while the centres merely facilitated implementation. The arrangement was not franchise service, as the centres had no independent representational right to commercially exploit the university&#039;s name or marks and acted under close academic supervision. No taxable service was rendered by the university because it received no consideration for a distinct service and the activity was intrinsically education-related. The service tax demand and penalties were therefore unsustainable.</description>
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