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    <title>2025 (3) TMI 578 - CESTAT MUMBAI</title>
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    <description>Pipeline transportation charges recovered for delivery of natural gas through the seller&#039;s own pipeline were not liable to service tax because the activity formed part of the sale transaction, not a separate service rendered to another person. Under the pre-negative list regime, the levy under Section 65(105)(zzz) required a taxable service for consideration, which was absent where gas was supplied under a sale contract and title and risk passed at the delivery point. Under the post-negative list regime, Section 66B continued to tax only services between distinct persons, while sale remained outside the definition of service. The charges were therefore incidental to sale and, if anything, includible in sale value, not taxable service consideration.</description>
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    <pubDate>Mon, 10 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 578 - CESTAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=767192</link>
      <description>Pipeline transportation charges recovered for delivery of natural gas through the seller&#039;s own pipeline were not liable to service tax because the activity formed part of the sale transaction, not a separate service rendered to another person. Under the pre-negative list regime, the levy under Section 65(105)(zzz) required a taxable service for consideration, which was absent where gas was supplied under a sale contract and title and risk passed at the delivery point. Under the post-negative list regime, Section 66B continued to tax only services between distinct persons, while sale remained outside the definition of service. The charges were therefore incidental to sale and, if anything, includible in sale value, not taxable service consideration.</description>
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