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    <title>2018 (6) TMI 385 - CESTAT MUMBAI</title>
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    <description>A lender&#039;s exposure fee under an external commercial borrowing was treated as part of loan pricing and therefore as interest, because it was linked to credit risk, cover percentage, repayment period and drawdown period rather than any identifiable appraisal, processing or other service to the borrower. On that basis, it was not liable to service tax under reverse charge. For other borrowing-related charges, penalty was unwarranted because the tax dispute involved a bona fide interpretational issue, and the tax with interest had already been paid before notice. In the absence of deliberate suppression or conscious evasion, penalty was not sustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=361558</link>
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