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    <title>2017 (5) TMI 822 - CESTAT MUMBAI</title>
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    <description>Rental charges for specialised containers used to receive helium gas from a foreign supplier were held not liable to service tax under supply of tangible goods for use on reverse charge. The containers remained under the appellant&#039;s effective control and possession during transport and unloading, were re-exported after use, and were deployed as part of the manufacturing and repacking process. The arrangement was therefore integrally connected with manufacture rather than an independent taxable service. The position was also revenue neutral because any service tax paid would have been available as credit against output duty. The demand was consequently unsustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=343084</link>
      <description>Rental charges for specialised containers used to receive helium gas from a foreign supplier were held not liable to service tax under supply of tangible goods for use on reverse charge. The containers remained under the appellant&#039;s effective control and possession during transport and unloading, were re-exported after use, and were deployed as part of the manufacturing and repacking process. The arrangement was therefore integrally connected with manufacture rather than an independent taxable service. The position was also revenue neutral because any service tax paid would have been available as credit against output duty. The demand was consequently unsustainable.</description>
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