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    <description>Transfer of technical information, technical assistance and technical know-how for setting up and operating a service centre was treated as outside consulting engineer service, because the transfer of technology for repair and maintenance operations did not fit that taxable category. The note also states that Notification No. 36/2004-ST, effective only from 1-1-2005, could not be used to sustain a demand for an earlier period. On that basis, the service tax demand was described as unsustainable both on merits and because the notification operated prospectively.</description>
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