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    <title>2026 (7) TMI 98 - GUJARAT HIGH COURT</title>
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    <description>Service tax could not be levied on negative debtor entries treated as alleged advance receipts where the records showed a current-account style accounting arrangement, supported by debit notes and invoices on which tax had already been discharged, and the department failed to prove transaction-wise that any taxable receipt had escaped assessment. The extended limitation period was also unavailable because the amounts were disclosed in the books and financial statements, earlier audits raised no objection, and there was no material showing suppression or wilful misstatement. On that basis, no substantial question of law arose and the Revenue&#039;s appeal failed.</description>
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