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    <description>Books and study materials sold separately from coaching services cannot be included in the taxable value of commercial training or coaching service when the evidence shows distinct publication and coaching activities. Certified accounts, sample invoices and fee receipts established that student receipts covered coaching charges only, while the sale of books and publications was a separate business activity. Mere accounting consolidation in the balance sheet was insufficient to justify clubbing the two components, so the service tax demand based on inclusion of study material value was unsustainable.</description>
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