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    <title>Strict construction of exemption notifications bars astronomy coaching from the culture exemption, with demand recomputed on a cum-tax basis.</title>
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    <description>Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word &quot;culture&quot; was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.</description>
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      <link>https://www.taxtmi.com/highlights?id=101153</link>
      <description>Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word &quot;culture&quot; was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.</description>
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