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    <title>2025 (7) TMI 1007 - Supreme Court</title>
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    <description>Extended limitation under section 73(1) of the Finance Act, 1994 could not be invoked because the Department failed to establish suppression, wilful misstatement or intent to evade tax; the assessee had disclosed its activities and corresponded with authorities, so the notice was time-barred. Enrolment, collection, processing and storage of umbilical cord blood stem cells were treated as healthcare services because they were intrinsically connected with diagnosis, treatment or care; the exemption under Notification No. 25/2012-Service Tax applied, and Notification No. 4/2014-Service Tax was treated as clarificatory for pending disputes. Since the demand failed and the services were exempt, interest and penalties were not leviable, and the deposited amount was refundable.</description>
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      <description>Extended limitation under section 73(1) of the Finance Act, 1994 could not be invoked because the Department failed to establish suppression, wilful misstatement or intent to evade tax; the assessee had disclosed its activities and corresponded with authorities, so the notice was time-barred. Enrolment, collection, processing and storage of umbilical cord blood stem cells were treated as healthcare services because they were intrinsically connected with diagnosis, treatment or care; the exemption under Notification No. 25/2012-Service Tax applied, and Notification No. 4/2014-Service Tax was treated as clarificatory for pending disputes. Since the demand failed and the services were exempt, interest and penalties were not leviable, and the deposited amount was refundable.</description>
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