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Contract Splits for Convenience, Not Service Classification; Artificial Bifurcation Deemed Unacceptable for Classification.

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....Classification of services - The terms of the contract in the instant case being categorical and the division of the amount payable in a ratio appears to be only for the convenience of the parties involved and therefore it cannot be concluded that the services rendered by the appellants are under two different heads. Such an artificial bifurcation is not acceptable.....