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    <description>Services provided for godown facilities to the Food Corporation of India were not treated as passive renting of immovable property because the arrangement required the provider to keep the premises storage-worthy, maintain records, insure stocks, and supply security and related facilities. On those terms, the activity was characterised as storage and warehousing rather than mere leasing. As the goods stored were agricultural produce, the service fell within the exempt storage and warehousing category, and service tax under renting of immovable property was held unsustainable.</description>
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