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of Demand of service tax - receipts generated from securitization agreements - receipts from ‘special purpose vehicles’ - Barring a bald assertion that ‘cash management’ has been undertaken, the adjudicating authority has not made any effort to analyse the nature and circumstances in which the contract with ‘special purpose vehicles’ undertook to provide such facility. - The levy of tax and imposition of detriment in the impugned order is without authority of law - AT
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