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    <description>VAT could not be levied on SIM replacement charges or lease line revenue collected by a telecom service provider because both receipts were treated as consideration for telecom services, not as separate sales of goods. SIM replacement was regarded as integral to activation and service provision, while lease line arrangements involved only permissive use in the course of service and did not amount to transfer of property in goods or transfer of the right to use goods. On that basis, the VAT levy on both items was unsustainable and the assessment orders and demand notices were set aside.</description>
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