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    <title>2025 (4) TMI 825 - CESTAT BANGALORE</title>
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    <description>The CESTAT Bangalore held that the appellant was liable to pay service tax on 100% of the Annual Technical Support (ATS) fee invoice value, rejecting their claim for liability on only 25% of the value for the period February 2007 to March 2009. The tribunal determined that ATS services were purely service-oriented with no goods element involved, distinguishing them from deemed sales under Article 366(29A) of the Constitution. Despite the appellant&#039;s correspondence with the department from December 2005 onwards regarding their position on paying service tax on 25% of the value, the tribunal upheld the Commissioner&#039;s decision requiring full service tax payment on the entire invoice value. The appeal was allowed in part.</description>
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    <pubDate>Wed, 19 Mar 2025 00:00:00 +0530</pubDate>
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      <title>2025 (4) TMI 825 - CESTAT BANGALORE</title>
      <link>https://www.taxtmi.com/caselaws?id=768911</link>
      <description>The CESTAT Bangalore held that the appellant was liable to pay service tax on 100% of the Annual Technical Support (ATS) fee invoice value, rejecting their claim for liability on only 25% of the value for the period February 2007 to March 2009. The tribunal determined that ATS services were purely service-oriented with no goods element involved, distinguishing them from deemed sales under Article 366(29A) of the Constitution. Despite the appellant&#039;s correspondence with the department from December 2005 onwards regarding their position on paying service tax on 25% of the value, the tribunal upheld the Commissioner&#039;s decision requiring full service tax payment on the entire invoice value. The appeal was allowed in part.</description>
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      <pubDate>Wed, 19 Mar 2025 00:00:00 +0530</pubDate>
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