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    <title>2026 (7) TMI 154 - CESTAT CHENNAI</title>
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    <description>Construction for educational institutions and Government welfare projects was held not to be taxable as commercial or industrial construction merely because fees, incidental revenue, or ancillary facilities such as shopping or canteen units existed; the demand failed except for the admitted reverse-charge liability on the specific subcontracted service. An accepted VCES 2013 declaration could not be reopened after the statutory period unless it was substantially false, so proceedings based on reopening were unsustainable. On limitation, a marginal mismatch between returns and accounts, with tax already paid before notice, did not establish suppression with intent to evade; the extended period and penalties were therefore not justified.</description>
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