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    <title>2025 (11) TMI 124 - CESTAT CHENNAI</title>
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    <description>Construction services for educational institutions were treated differently across the service tax timeline: for the period up to 01.07.2012, works contract taxability depended on whether the construction was primarily for commerce or industry, and the Revenue had to prove that element; in the absence of such proof, the levy did not apply. After 01.07.2012, the revised works contract definition no longer turned on the commerce or industry test, so the services fell within the taxable net. Valuation had to exclude the cost of free-supplied materials, receipts were to be treated as cum-tax where tax was not separately collected, and suppression through non-registration, non-filing and non-payment supported the extended period and penalties.</description>
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