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    <title>2026 (5) TMI 1231 - CESTAT NEW DELHI</title>
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    <description>CENVAT credit of service tax paid on group medical insurance for members was admissible because Rule 3 of the CENVAT Credit Rules, 2004 permits credit on input services used for output services, and the exclusion in Rule 2(l) was wrongly applied where the arrangement related to members, not employees. The intermediary structure did not change the tax character of the transaction, and denial of credit was unsustainable. The extended period under Section 73(1) of the Finance Act, 1994 could not be invoked because the relevant facts were disclosed in ST-3 returns and known through audit, with no evidence of suppression or intent to evade. The demand was time-barred.</description>
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      <link>https://www.taxtmi.com/caselaws?id=792029</link>
      <description>CENVAT credit of service tax paid on group medical insurance for members was admissible because Rule 3 of the CENVAT Credit Rules, 2004 permits credit on input services used for output services, and the exclusion in Rule 2(l) was wrongly applied where the arrangement related to members, not employees. The intermediary structure did not change the tax character of the transaction, and denial of credit was unsustainable. The extended period under Section 73(1) of the Finance Act, 1994 could not be invoked because the relevant facts were disclosed in ST-3 returns and known through audit, with no evidence of suppression or intent to evade. The demand was time-barred.</description>
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