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    <description>Home base component agreements were examined under the service tax provisions and Article 366(29A)(d), but the arrangement was not accepted as a true transfer of right to use goods or a deemed sale because the supplier retained contractual controls and the record did not establish VAT treatment as a sale. On that basis, the normal-period service tax demand was sustained. By contrast, the extended period of limitation and the related penalty were unsustainable because the dispute had been known to the Department and there was no established suppression of facts with intent to evade tax; those additions were set aside.</description>
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