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    <title>2025 (7) TMI 73 - CESTAT NEW DELHI</title>
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    <description>Composite works contracts involving supply of goods and services in electrical works were treated as distinct from service contracts simpliciter, so service tax could not be sustained for the period before 01.06.2007. The extended limitation period was held unavailable because the record showed the taxability of works contract activities was under substantial dispute, and mere non-payment or non-filing did not establish suppression with intent to evade tax. Cum-tax benefit was admissible on the surviving demand, and penalties were not sustainable once suppression and extended limitation failed. The demand was therefore confined to the normal period with cum-tax relief, while the balance demand and penalties were set aside.</description>
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      <link>https://www.taxtmi.com/caselaws?id=774005</link>
      <description>Composite works contracts involving supply of goods and services in electrical works were treated as distinct from service contracts simpliciter, so service tax could not be sustained for the period before 01.06.2007. The extended limitation period was held unavailable because the record showed the taxability of works contract activities was under substantial dispute, and mere non-payment or non-filing did not establish suppression with intent to evade tax. Cum-tax benefit was admissible on the surviving demand, and penalties were not sustainable once suppression and extended limitation failed. The demand was therefore confined to the normal period with cum-tax relief, while the balance demand and penalties were set aside.</description>
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