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    <title>2026 (7) TMI 1360 - CESTAT NEW DELHI</title>
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    <description>Non-payment of service tax on part of the consideration received for taxable security agency services may justify extended limitation and penalty where the conduct shows intent to evade tax. The notes state that partial payment during the same financial year negated the claimed bona fide belief that a welfare-oriented cooperative society was exempt from service-tax liability. Its bye-laws contemplated net profit, and cooperative status did not distinguish it from a commercial entity. Service tax was payable on the gross amount received under Section 67 of the Finance Act, 1994; accordingly, the extended recovery period, tax demand, and penalty were considered sustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=795474</link>
      <description>Non-payment of service tax on part of the consideration received for taxable security agency services may justify extended limitation and penalty where the conduct shows intent to evade tax. The notes state that partial payment during the same financial year negated the claimed bona fide belief that a welfare-oriented cooperative society was exempt from service-tax liability. Its bye-laws contemplated net profit, and cooperative status did not distinguish it from a commercial entity. Service tax was payable on the gross amount received under Section 67 of the Finance Act, 1994; accordingly, the extended recovery period, tax demand, and penalty were considered sustainable.</description>
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