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    <title>Service tax demand quashed; advances held loans; RCM time-barred; only reduced late fee on ST-3 upheld</title>
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    <description>The CESTAT allowed the appeal of M/s X against the impugned order, setting aside the service tax demand of Rs. 2,22,51,053/- on amounts wrongly treated as taxable advances, holding them to be refundable loans not linked to any taxable service. The Tribunal further held that the service tax demand of Rs. 16,44,878/- under RCM on imported services was unsustainable, being a revenue-neutral situation, and also barred by limitation as the extended period could not be invoked through a third SCN on the same issue. Consequently, interest and penalties under Sections 77 and 78 of the Finance Act, 1994 were quashed. However, late fee of Rs. 21,700/- for delayed ST-3 returns was upheld, subject to adjustment of Rs. 7,900/- already paid.</description>
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    <pubDate>Sat, 22 Nov 2025 07:36:35 +0530</pubDate>
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      <title>Service tax demand quashed; advances held loans; RCM time-barred; only reduced late fee on ST-3 upheld</title>
      <link>https://www.taxtmi.com/highlights?id=94386</link>
      <description>The CESTAT allowed the appeal of M/s X against the impugned order, setting aside the service tax demand of Rs. 2,22,51,053/- on amounts wrongly treated as taxable advances, holding them to be refundable loans not linked to any taxable service. The Tribunal further held that the service tax demand of Rs. 16,44,878/- under RCM on imported services was unsustainable, being a revenue-neutral situation, and also barred by limitation as the extended period could not be invoked through a third SCN on the same issue. Consequently, interest and penalties under Sections 77 and 78 of the Finance Act, 1994 were quashed. However, late fee of Rs. 21,700/- for delayed ST-3 returns was upheld, subject to adjustment of Rs. 7,900/- already paid.</description>
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      <pubDate>Sat, 22 Nov 2025 07:36:35 +0530</pubDate>
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