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    <title>2026 (4) TMI 1356 - CESTAT BANGALORE</title>
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    <description>Additional contingent bonus payments under a share purchase arrangement were treated according to their real character: because they were separately stipulated, linked to future turnover and managerial continuance, and payable over and above the share price to the individual sellers, they were regarded as consideration for marketing services and made liable to service tax under Reverse Charge Mechanism. Non-disclosure of the liability, discovered only through investigation, was treated as suppression with intent to evade tax, so the extended period of limitation was upheld. The penalty structure was nevertheless modified because the commission-related demand had been paid with interest before the show cause notice, resulting in reduction of one penalty and setting aside of another.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790287</link>
      <description>Additional contingent bonus payments under a share purchase arrangement were treated according to their real character: because they were separately stipulated, linked to future turnover and managerial continuance, and payable over and above the share price to the individual sellers, they were regarded as consideration for marketing services and made liable to service tax under Reverse Charge Mechanism. Non-disclosure of the liability, discovered only through investigation, was treated as suppression with intent to evade tax, so the extended period of limitation was upheld. The penalty structure was nevertheless modified because the commission-related demand had been paid with interest before the show cause notice, resulting in reduction of one penalty and setting aside of another.</description>
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