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    <title>2026 (4) TMI 1829 - CESTAT CHANDIGARH</title>
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    <description>Government-created societies performing statutory public functions were treated as instrumentalities of the State, with fees collected characterised as statutory fees rather than commercial consideration. On that basis, services linked to functions entrusted to municipalities and panchayats were held to fall within the exemption framework under Notification No. 25/2012-ST, as amended, and denial of exemption was unsustainable. The dispute was also held to be interpretational, with no suppression, fraud, collusion, or intent to evade tax; accordingly, the extended limitation period and penalties under the Finance Act, 1994 were held inapplicable. The demand, interest and penalties were set aside, and consequential relief followed.</description>
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      <link>https://www.taxtmi.com/caselaws?id=790760</link>
      <description>Government-created societies performing statutory public functions were treated as instrumentalities of the State, with fees collected characterised as statutory fees rather than commercial consideration. On that basis, services linked to functions entrusted to municipalities and panchayats were held to fall within the exemption framework under Notification No. 25/2012-ST, as amended, and denial of exemption was unsustainable. The dispute was also held to be interpretational, with no suppression, fraud, collusion, or intent to evade tax; accordingly, the extended limitation period and penalties under the Finance Act, 1994 were held inapplicable. The demand, interest and penalties were set aside, and consequential relief followed.</description>
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