Revenue sharing arrangements structured on a principal to...

Revenue sharing arrangements structured on a principal to principal basis for healthcare business support and infrastructural services do not attract service tax under the business support services classification; the reasoning relies on prior tribunal and departmental appellate findings and Circular No.109/03/2009 ST treating principal to principal transactions as not constituting a service, and identical tribunal decisions on comparable agreements. Because the department did not appeal earlier favorable orders, those orders attained finality and the impugned demand was set aside; the appeal was allowed with consequential relief as per law.

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