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    <title>2026 (7) TMI 455 - CESTAT KOLKATA</title>
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    <description>Service tax disputes arising from public infrastructure projects under Notification No. 25/2012-ST were treated as exemption and classification matters, not cases of deliberate suppression. The extended limitation period under the proviso to Section 73(1) was held unavailable because the transactions were recorded and no fraud, wilful misstatement or intent to evade was shown. Exemption was upheld for the food grain godown, integrated farmers&#039; market complex and Jawahar Navodaya Vidyalaya work, while the mobilization advance was treated as temporary financial accommodation and not taxable value. GTA, royalty under reverse charge and trade licence fee demands also failed, and penalty under Section 78 was not leviable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=794569</link>
      <description>Service tax disputes arising from public infrastructure projects under Notification No. 25/2012-ST were treated as exemption and classification matters, not cases of deliberate suppression. The extended limitation period under the proviso to Section 73(1) was held unavailable because the transactions were recorded and no fraud, wilful misstatement or intent to evade was shown. Exemption was upheld for the food grain godown, integrated farmers&#039; market complex and Jawahar Navodaya Vidyalaya work, while the mobilization advance was treated as temporary financial accommodation and not taxable value. GTA, royalty under reverse charge and trade licence fee demands also failed, and penalty under Section 78 was not leviable.</description>
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