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    <title>2025 (8) TMI 173 - CESTAT BANGALORE</title>
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    <description>A permanent assignment of telecast and broadcasting rights in a cinematographic film is distinguished from a temporary transfer or permission to use copyright, so it falls outside taxable copyright service. Film screening and exhibition in a revenue-sharing arrangement is not, by itself, business auxiliary service; taxability was noted only in a fixed-rent theatre lease situation, which was not alleged, and the classification was therefore unsustainable. The extended limitation period requires suppression, misstatement, or deliberate evasion, and those ingredients were absent where the demand rested on records supplied by the assessee and the tax position was debatable. The commentary concludes that the demand could not be sustained on classification or limitation grounds.</description>
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      <description>A permanent assignment of telecast and broadcasting rights in a cinematographic film is distinguished from a temporary transfer or permission to use copyright, so it falls outside taxable copyright service. Film screening and exhibition in a revenue-sharing arrangement is not, by itself, business auxiliary service; taxability was noted only in a fixed-rent theatre lease situation, which was not alleged, and the classification was therefore unsustainable. The extended limitation period requires suppression, misstatement, or deliberate evasion, and those ingredients were absent where the demand rested on records supplied by the assessee and the tax position was debatable. The commentary concludes that the demand could not be sustained on classification or limitation grounds.</description>
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