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    <title>2025 (3) TMI 842 - CESTAT NEW DELHI</title>
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    <description>CESTAT New Delhi allowed the appeal, setting aside service tax demands on multiple grounds. The tribunal held that franchise income from central rights does not constitute Business Support Services as no service is provided between franchise agreement members. Payments to overseas cricket professionals for promotional activities are not taxable under Business Support Services when players are primarily engaged for cricket, following established precedent that composite contracts without machinery provisions to separate non-taxable services remain non-taxable. Player release fees to cricket boards and transfer fees between franchisees do not qualify as Manpower Recruitment or Supply Agency Services since neither cricket boards nor franchisees engage in manpower recruitment services. Additionally, the demand was time-barred as the department had prior knowledge of all relevant transactions and the appellant had disclosed all facts without suppression.</description>
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    <pubDate>Thu, 13 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (3) TMI 842 - CESTAT NEW DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=767456</link>
      <description>CESTAT New Delhi allowed the appeal, setting aside service tax demands on multiple grounds. The tribunal held that franchise income from central rights does not constitute Business Support Services as no service is provided between franchise agreement members. Payments to overseas cricket professionals for promotional activities are not taxable under Business Support Services when players are primarily engaged for cricket, following established precedent that composite contracts without machinery provisions to separate non-taxable services remain non-taxable. Player release fees to cricket boards and transfer fees between franchisees do not qualify as Manpower Recruitment or Supply Agency Services since neither cricket boards nor franchisees engage in manpower recruitment services. Additionally, the demand was time-barred as the department had prior knowledge of all relevant transactions and the appellant had disclosed all facts without suppression.</description>
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      <pubDate>Thu, 13 Mar 2025 00:00:00 +0530</pubDate>
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