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    <title>2026 (7) TMI 1355 - CESTAT CHENNAI</title>
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    <description>Penalties for non-payment of service tax on overseas consultancy or commission services are discussed as unsustainable where foreign remittances were disclosed in the balance sheet and identified during audit, without material showing wilful suppression or intent to evade tax. The discussion states that extended limitation could not apply in those circumstances. It further notes that payment of tax with interest, availability of reverse-charge tax as Cenvat credit, and resulting revenue neutrality supported the position. Interpretational uncertainty over reverse-charge taxation of services received from abroad was also treated as reasonable cause, leading to setting aside penalties under the Cenvat Credit Rules and the Finance Act.</description>
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      <description>Penalties for non-payment of service tax on overseas consultancy or commission services are discussed as unsustainable where foreign remittances were disclosed in the balance sheet and identified during audit, without material showing wilful suppression or intent to evade tax. The discussion states that extended limitation could not apply in those circumstances. It further notes that payment of tax with interest, availability of reverse-charge tax as Cenvat credit, and resulting revenue neutrality supported the position. Interpretational uncertainty over reverse-charge taxation of services received from abroad was also treated as reasonable cause, leading to setting aside penalties under the Cenvat Credit Rules and the Finance Act.</description>
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