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    <title>2025 (11) TMI 1279 - CESTAT AHMEDABAD</title>
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    <description>Construction of residential quarters for government personnel through government-controlled entities was treated as falling within the residential-complex exclusion for personal use, and the pre-01.06.2007 construction activity was not taxable in the manner demanded; the related service tax demand was set aside. For GTA services, exemption under Notification No. 34/2004-Service Tax depended on strict proof of the notification conditions, and on the facts the exemption claim failed, so the tax demand with interest was upheld. Penalties under Sections 76 and 77 were sustained because tax default and non-compliance were established, while penalty under Section 78 was set aside on the circumstances.</description>
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      <description>Construction of residential quarters for government personnel through government-controlled entities was treated as falling within the residential-complex exclusion for personal use, and the pre-01.06.2007 construction activity was not taxable in the manner demanded; the related service tax demand was set aside. For GTA services, exemption under Notification No. 34/2004-Service Tax depended on strict proof of the notification conditions, and on the facts the exemption claim failed, so the tax demand with interest was upheld. Penalties under Sections 76 and 77 were sustained because tax default and non-compliance were established, while penalty under Section 78 was set aside on the circumstances.</description>
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