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    <title>2026 (4) TMI 150 - CESTAT HYDERABAD</title>
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    <description>Penalties for delayed service tax compliance were held unsustainable where liability for renting of immovable property service arose from a retrospective levy and the non-payment reflected a bona fide interpretational dispute rather than intent to evade. The Tribunal found reasonable cause for the default under Section 80(1) of the Finance Act, 1994, and noted that the later immunity framework in Section 80(2) did not displace that protection. It also held that the ingredients for penalty under Section 78 were absent. On that basis, penalties under Sections 76, 77 and 78 were set aside in favour of the assessee.</description>
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      <title>2026 (4) TMI 150 - CESTAT HYDERABAD</title>
      <link>https://www.taxtmi.com/caselaws?id=789081</link>
      <description>Penalties for delayed service tax compliance were held unsustainable where liability for renting of immovable property service arose from a retrospective levy and the non-payment reflected a bona fide interpretational dispute rather than intent to evade. The Tribunal found reasonable cause for the default under Section 80(1) of the Finance Act, 1994, and noted that the later immunity framework in Section 80(2) did not displace that protection. It also held that the ingredients for penalty under Section 78 were absent. On that basis, penalties under Sections 76, 77 and 78 were set aside in favour of the assessee.</description>
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