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    <title>2026 (4) TMI 1511 - CESTAT ALLAHABAD</title>
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    <description>Services rendered to educational institutions were treated as falling within the negative list, and security services to those institutions were also covered by the applicable exemption notification; services supplied to a body corporate were, if taxable at all, liable under reverse charge in the recipient&#039;s hands. On that basis, the service tax demand was unsustainable. The extended limitation period was also unavailable because the appellant was registered, filed returns regularly, maintained records, and the department relied on public income tax data rather than concealed material, so suppression of facts was not established. The demand, including consequential interest and penalties, could not be sustained.</description>
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