https://www.taxtmi.com/caselaws?id=772009 CESTAT New Delhi held that conversion charges comprising interest and depreciation paid under a job work agreement do not constitute taxable service under "renting of immovable property." The Tribunal emphasized that written contract terms cannot be varied and the agreement was solely for manufacturing purposes, not property rental. Following SC precedent in Haryana Power Purchase Centre, the Tribunal ruled that service tax requires transaction-specific consideration with contractual reciprocity. The manufacturing activity qualified for exemption under Section 66D(f) and Notification No. 25/2012-ST. Revenue cannot rely on balance sheet entries to establish service tax liability without proving actual rental arrangement. Appeals allowed, impugned order set aside. en-us Mon, 26 May 2025 00:00:00 +0530 Mon, 26 May 2025 17:22:13 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=772009 CESTAT New Delhi held that conversion charges comprising interest and depreciation paid under a job work agreement do not constitute taxable service under "renting of immovable property." The Tribunal emphasized that written contract terms cannot be varied and the agreement was solely for manufacturing purposes, not property rental. Following SC precedent in Haryana Power Purchase Centre, the Tribunal ruled that service tax requires transaction-specific consideration with contractual reciprocity. The manufacturing activity qualified for exemption under Section 66D(f) and Notification No. 25/2012-ST. Revenue cannot rely on balance sheet entries to establish service tax liability without proving actual rental arrangement. Appeals allowed, impugned order set aside. Case-Laws Service Tax Mon, 26 May 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=772009