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    <title>2026 (8) TMI 791 - CESTAT HYDERABAD</title>
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    <description>Time-share arrangements granting only contractual accommodation rights, without shareholding, voting, management or genuine membership privileges, fall outside Club or Association Service. Customers described contractually as members do not become company members unless recognised under company law and recorded in the register of members. The later introduction of Short Term Accommodation Service supports the view that time-share accommodation was not taxable under the earlier club-service entry. Where tax and interest for other taxable services are paid before a show-cause notice and fraud, collusion or wilful suppression is not established, Section 73(3) protects against further proceedings and penalties. Penalties for suppression-based defaults are unsustainable where the dispute is interpretational and transactions are regularly recorded.</description>
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      <link>https://www.taxtmi.com/caselaws?id=796917</link>
      <description>Time-share arrangements granting only contractual accommodation rights, without shareholding, voting, management or genuine membership privileges, fall outside Club or Association Service. Customers described contractually as members do not become company members unless recognised under company law and recorded in the register of members. The later introduction of Short Term Accommodation Service supports the view that time-share accommodation was not taxable under the earlier club-service entry. Where tax and interest for other taxable services are paid before a show-cause notice and fraud, collusion or wilful suppression is not established, Section 73(3) protects against further proceedings and penalties. Penalties for suppression-based defaults are unsustainable where the dispute is interpretational and transactions are regularly recorded.</description>
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