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    <title>2026 (3) TMI 1530 - CESTAT CHENNAI</title>
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    <description>Recoveries of 0.5% from sub-contractors&#039; bills, though described as administrative charges or rebate, were treated as consideration for taxable support services because they were linked to bill value and were unsupported by contracts, invoices, or proof of prior third-party expenditure. The CSR and reimbursement arguments failed for lack of evidence, and CSR treatment did not render an otherwise taxable service non-taxable. Non-disclosure of the recoveries in returns and failure to produce supporting records established suppression of material facts, justifying the extended limitation under the proviso to section 73(1) and sustaining penalty under section 78, while relief under section 77 remained undisturbed.</description>
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      <description>Recoveries of 0.5% from sub-contractors&#039; bills, though described as administrative charges or rebate, were treated as consideration for taxable support services because they were linked to bill value and were unsupported by contracts, invoices, or proof of prior third-party expenditure. The CSR and reimbursement arguments failed for lack of evidence, and CSR treatment did not render an otherwise taxable service non-taxable. Non-disclosure of the recoveries in returns and failure to produce supporting records established suppression of material facts, justifying the extended limitation under the proviso to section 73(1) and sustaining penalty under section 78, while relief under section 77 remained undisturbed.</description>
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