Point of taxation - Continuous supply - The appellant contended...

Point of taxation - Continuous supply - The appellant contended that their service contract with ONGC was a continuous supply of service and that the point of taxation had not been triggered, as they had not yet delivered oil/gas to ONGC. They argued that the activities undertaken were intermediate steps toward fulfilling the contract's scope and did not constitute a taxable service per se, as they had not yet received consideration for the supposed services rendered. - The tribunal found merit in the appellant's arguments, emphasizing the nature of the contract as a continuous supply of service, where taxation could only be applied upon the completion of specific milestones. - Demadn of service tax set aside.