https://www.taxtmi.com/caselaws?id=783175 Reverse charge service tax on software-related services received from a foreign supplier was held unsustainable where the Indian subsidiary was treated as only providing incidental support and did not justify fastening liability on the recipient on a permanent establishment theory. The Tribunal also held that the demand could not be extended by invoking the extended period of limitation because the dispute was interpretational and the record did not show wilful suppression or mala fide intent to evade tax. The service tax demand was therefore set aside on both merits and limitation, with consequential relief. en-us Wed, 10 Dec 2025 00:00:00 +0530 Thu, 11 Dec 2025 08:55:41 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=783175 Reverse charge service tax on software-related services received from a foreign supplier was held unsustainable where the Indian subsidiary was treated as only providing incidental support and did not justify fastening liability on the recipient on a permanent establishment theory. The Tribunal also held that the demand could not be extended by invoking the extended period of limitation because the dispute was interpretational and the record did not show wilful suppression or mala fide intent to evade tax. The service tax demand was therefore set aside on both merits and limitation, with consequential relief. Case-Laws Service Tax Wed, 10 Dec 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=783175