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    <description>Extended limitation under the proviso to Section 73(1) of the Finance Act, 1994 was stated to be unavailable because the records disclosed the transactions, the assessee cooperated with audit, and the department did not establish fraud, suppression, wilful misstatement, or intent to evade tax. Services linked to an exhibition held in Switzerland were stated to fall under the place-of-provision rule for events, so provision was outside the taxable territory and service tax was not leviable. The software licence transaction was treated as a sale with VAT on the sale element and service tax only on the service component, making a full-value service tax levy unsustainable.</description>
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      <description>Extended limitation under the proviso to Section 73(1) of the Finance Act, 1994 was stated to be unavailable because the records disclosed the transactions, the assessee cooperated with audit, and the department did not establish fraud, suppression, wilful misstatement, or intent to evade tax. Services linked to an exhibition held in Switzerland were stated to fall under the place-of-provision rule for events, so provision was outside the taxable territory and service tax was not leviable. The software licence transaction was treated as a sale with VAT on the sale element and service tax only on the service component, making a full-value service tax levy unsustainable.</description>
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