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    <title>2026 (1) TMI 1442 - CESTAT AHMEDABAD</title>
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    <description>Refund claim concerns service tax paid during a departmental enquiry under the voluntary payment regime; legal point is that voluntary payment made under the statutory provision and communicated with applicable administrative instructions precludes challenge to belated refund where payment was made to comply with inquiry, and such payment does not permit issuance of a show cause notice to negate refund entitlement. Reverse charge allocation and the Place of Provision of Services Rules were considered for taxability determination but did not alter the consequence of voluntary payment. The appeal challenging the administrative denial of refund was dismissed on these legal bases.</description>
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      <description>Refund claim concerns service tax paid during a departmental enquiry under the voluntary payment regime; legal point is that voluntary payment made under the statutory provision and communicated with applicable administrative instructions precludes challenge to belated refund where payment was made to comply with inquiry, and such payment does not permit issuance of a show cause notice to negate refund entitlement. Reverse charge allocation and the Place of Provision of Services Rules were considered for taxability determination but did not alter the consequence of voluntary payment. The appeal challenging the administrative denial of refund was dismissed on these legal bases.</description>
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