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    <title>2026 (2) TMI 785 - CESTAT KOLKATA</title>
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    <description>Horticulture and garden maintenance services-including watering, weeding, manuring, pruning and plant protection-are treated as agricultural activity and fall within the negative list exemption under Section 66D(d) read with the definition in Section 65B(3); accordingly demands on such turnover were disallowed as unsustainable and time-barred in absence of evidence of deliberate evasion. Separately, manpower supply services were assessed under the applicable partial valuation method, producing a residual tax liability which the appellant must pay with interest; however, penalties and invocation of the extended period were set aside for lack of proof of wilful suppression.</description>
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      <description>Horticulture and garden maintenance services-including watering, weeding, manuring, pruning and plant protection-are treated as agricultural activity and fall within the negative list exemption under Section 66D(d) read with the definition in Section 65B(3); accordingly demands on such turnover were disallowed as unsustainable and time-barred in absence of evidence of deliberate evasion. Separately, manpower supply services were assessed under the applicable partial valuation method, producing a residual tax liability which the appellant must pay with interest; however, penalties and invocation of the extended period were set aside for lack of proof of wilful suppression.</description>
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