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Supreme Court of India 2025-07-14 allowed

PVT. LTD vs COMMISSIONER OF CENTRAL EXCISE AND

Bench: 2 — J.B. Pardiwala, R. Mahadevan

In Brief

A private company engaged in umbilical cord blood stem cell banking sought exemption from service tax for the period July 2012 to February 2014. The Revenue Department demanded tax and penalties, arguing the services did not qualify as 'Healthcare Services'. The Supreme Court allowed the appeal, holding that stem cell banking services are preventive and curative healthcare services covered under exemption Notification 2012. The Court found the show cause notice was time-barred under the ordinary limitation period, as the Department failed to establish fraud or suppression. The Court set aside all penalties and ordered refund of the deposited amount within four weeks.

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Service Tax Exemptions Healthcare Services Stem Cell Banking Limitation Period Extended Limitation Fraud and Suppression Penalties Tax Evasion Statutory Interpretation

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