Renting of immovable property classification prevailed where the entire sugar factory was leased with plant and machinery.

Leasing the entire sugar factory together with plant and machinery was treated as renting of immovable property, because the arrangement involved letting out the whole factory premises rather than merely providing isolated infrastructure support. The classification as Business Support Service was rejected on those facts, and the lower appellate authority's view was upheld, so the demand did not survive.

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Issues: Whether leasing out the entire sugar factory along with plant and machinery amounted to Business Support Service (Providing Infrastructure), or was more appropriately classifiable as Renting of Immovable Property service.

Analysis: The respondent had leased out the entire factory to another entity. The Revenue's case was that the arrangement constituted provision of infrastructure support because the factory was leased along with machinery. The deciding factor was that the whole factory, and not merely machinery or isolated infrastructure, had been let out. On those facts, the activity was held to fall within Renting of Immovable Property service rather than Business Support Service.

Conclusion: The classification adopted by the lower appellate authority was upheld and the demand did not survive.

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