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    <title>2026 (7) TMI 524 - CESTAT KOLKATA</title>
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    <description>Construction contracts were treated as eligible for exemption under Notification No. 25/2012-Service Tax where the contemporaneous record showed that the quotation and tender process pre-dated the cutoff date, and the Department failed to rebut that chronology; the demand therefore failed on merits. The Tribunal also held that the extended limitation period was unavailable because the appellant had consistently disclosed its exemption claim, had not collected service tax from the recipient, and the record showed no deliberate suppression or intent to evade tax; the demand was time-barred. Penalty was set aside and consequential relief followed in accordance with law.</description>
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      <title>2026 (7) TMI 524 - CESTAT KOLKATA</title>
      <link>https://www.taxtmi.com/caselaws?id=794638</link>
      <description>Construction contracts were treated as eligible for exemption under Notification No. 25/2012-Service Tax where the contemporaneous record showed that the quotation and tender process pre-dated the cutoff date, and the Department failed to rebut that chronology; the demand therefore failed on merits. The Tribunal also held that the extended limitation period was unavailable because the appellant had consistently disclosed its exemption claim, had not collected service tax from the recipient, and the record showed no deliberate suppression or intent to evade tax; the demand was time-barred. Penalty was set aside and consequential relief followed in accordance with law.</description>
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