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2005 (3) TMI 603 - CESTAT, BANGALOREExtract: .......ely. Hence the value of software both application and systems is not includible in the value of DCS. Moreover, there is absolutely no justification for invoking the extended period and also imposing penalty. In the circumstances of the case the OIO has no merits. We allow the appeal with consequential relief. (Pronounced in open Court on 31-3-2005)
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