VCES finality and non-commercial construction classification defeat most service tax demands, while only admitted manpower supply tax survives

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....Construction for educational institutions and public welfare projects was treated as non-commercial: works for a charitable medical college, police housing and allied welfare facilities did not become taxable merely because fees were collected, incidental revenue arose, or a small shopping or canteen component existed. An accepted VCES declaration could not be reopened as "substantially false" merely because the Department later took a different valuation or interpretational view, so finality attached to the declaration. On limitation and penalty, minor reconciliation differences between the profit and loss account and ST-3 returns, together with payment before notice and absence of suppression, defeated extended limitation and consequential penalties; only the admitted balance manpower-supply liability survived with interest, subject to limitation.....