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    <title>2026 (7) TMI 1001 - CESTAT KOLKATA</title>
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    <description>Cleaning of railway stations and mechanised coaches was not taxable as cleaning service before 1 July 2012 because Indian Railways was not a commercial concern and railway coaches were not covered commercial or industrial premises or assets; the service was exempt thereafter as sanitation, conservancy and public-health activity. On-board housekeeping, including cleaning, disinfection and bedroll distribution, qualified for the Government-service exemption after 1 July 2012. For the earlier period, extended limitation could not apply because the Department already knew the relevant facts from an earlier notice, so suppression could not be alleged. Amounts connected with payment disputes were not retained service tax, and no unpaid tax collection was established. All demands, interest and penalties were set aside.</description>
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      <description>Cleaning of railway stations and mechanised coaches was not taxable as cleaning service before 1 July 2012 because Indian Railways was not a commercial concern and railway coaches were not covered commercial or industrial premises or assets; the service was exempt thereafter as sanitation, conservancy and public-health activity. On-board housekeeping, including cleaning, disinfection and bedroll distribution, qualified for the Government-service exemption after 1 July 2012. For the earlier period, extended limitation could not apply because the Department already knew the relevant facts from an earlier notice, so suppression could not be alleged. Amounts connected with payment disputes were not retained service tax, and no unpaid tax collection was established. All demands, interest and penalties were set aside.</description>
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