Wet lease arrangements for CNG compressors and related equipment...

Wet lease arrangements for CNG compressors and related equipment constitute supply of tangible goods service where the supplier installs, operates and maintains the equipment, retaining possession and effective control; customers therefore receive use of equipment rather than a transferable right to use it. Service tax liability applies to the transactions for the relevant periods. Extended limitation may be invoked where contractual terms and applicable provisions identify the service as taxable, and payment of sales tax under a different contractual understanding does not remove service tax liability; suppression concerning a High Court judgment also supported the extended period. A rectification order addressing one show cause notice may merge with the original adjudication order where it forms part of that adjudication and the original findings stand upheld by the High Court.