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    <title>2026 (5) TMI 1513 - CESTAT KOLKATA</title>
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    <description>A clarificatory amendment to Rule 2(l) expanding input service to cover sales commission services was applied retrospectively, so Cenvat credit on commission-based sales services was admissible and the credit denial failed. Because the credit was taken on a bona fide belief of admissibility and no suppression of facts with intent to evade duty was established, the extended period of limitation was inapplicable and the demand was time-barred. As the underlying demand could not stand, the personal penalty under Rule 26 also failed and was set aside.</description>
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      <description>A clarificatory amendment to Rule 2(l) expanding input service to cover sales commission services was applied retrospectively, so Cenvat credit on commission-based sales services was admissible and the credit denial failed. Because the credit was taken on a bona fide belief of admissibility and no suppression of facts with intent to evade duty was established, the extended period of limitation was inapplicable and the demand was time-barred. As the underlying demand could not stand, the personal penalty under Rule 26 also failed and was set aside.</description>
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