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    <title>2026 (6) TMI 1231 - CESTAT HYDERABAD</title>
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    <description>Composite works contracts involving supply of machinery and components with erection, installation and commissioning were treated as arrangements involving both goods and services, not pure service contracts. On that basis, service tax was held not leviable on such contracts for the period before 01.06.2007, when works contract service was introduced and no machinery existed to segregate the service element from the goods element. The extended limitation period was held unsustainable because the dispute was interpretational, regular records were maintained, VAT was paid on the goods portion, and there was no suppression or intent to evade. Penalties also failed for want of fraud, wilful misstatement, or deliberate suppression.</description>
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