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The appellant, engaged in providing a bouquet of services, was held liable to pay service tax on Renting of Immovable Property Service (RIPS). The tribunal rejected the appellant's claim of rendering sovereign functions, emphasizing that the appellant operates as a commercial entity and cannot selectively avoid tax liability. The agreement characterized as a commercial arrangement, with rental termed as user charges or license fees, does not exempt the appellant from service tax. The invocation of the extended period of limitation was upheld, as the appellant was aware of its tax obligations, having registered and paid service tax on other services. The attempt to circumvent tax liability on RIPS was deemed unjustified, and the appellant's appeal was dismissed in its entirety.