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    <title>2026 (6) TMI 1423 - CESTAT HYDERABAD</title>
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    <description>A service tax demand based on a mere mismatch between profit and loss figures and ST-3 returns was held unsustainable because the notice did not clearly identify the taxable service, charging provision, classification, or basis of computation. Hybrid seeds were treated as continuing to qualify as agricultural produce, since processing for preservation, grading, treatment, and germination quality did not create a new commercial commodity. Freight and loading-unloading charges were not shown to attract service tax on the record, and the interpretational nature of the dispute meant the extended limitation period and penalties were not invocable. The demand, interest, and penalties were set aside.</description>
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      <description>A service tax demand based on a mere mismatch between profit and loss figures and ST-3 returns was held unsustainable because the notice did not clearly identify the taxable service, charging provision, classification, or basis of computation. Hybrid seeds were treated as continuing to qualify as agricultural produce, since processing for preservation, grading, treatment, and germination quality did not create a new commercial commodity. Freight and loading-unloading charges were not shown to attract service tax on the record, and the interpretational nature of the dispute meant the extended limitation period and penalties were not invocable. The demand, interest, and penalties were set aside.</description>
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